A Practical Summary Of The July 2017 Oecd Transfer Pricing Guidelines

Author : Johann H. Müller
Publisher : Unknown
Page : 160 pages
File Size : 51,8 Mb
Release : 2017-07-26
Category : Electronic
ISBN : 1521937672

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A Practical Summary of the July 2017 OECD Transfer Pricing Guidelines by Johann H. Müller Pdf

How many of us still have time to read 600+ page guidelines? How many of us have time to take those guidelines and combine them with chapters adopted after the guidelines were published? How does a student begin to study a work of this size, without getting hopelessly lost? This book reflects my love for systematic thinking and reducing clutter. It is aimed at giving fast, accurate, information through diagrams and summaries.In this book, the 2017 OECD Transfer Pricing Guidelines are summarized three times: first as a one-page overview, then as a longer executive summary and finally as an extended summary of most of the paragraphs of the 2017 OECD Transfer Pricing Guidelines. The extended summary references the actual paragraphs in the 2017 OECD Transfer Pricing Guidelines. As the 2017 OECD Transfer Pricing Guidelines is a live document, which is continuously updated, I will substitute existing the 2017 OECD Transfer Pricing Guidelines chapters and paragraphs with draft and final material published after 2017. These texts are clearly marked and will first concern the profit allocation to PEs, the profit split method and financial transactions, when those documents are finalised by the OECD.All references within the book are hyperlinked for fast and easy reading between texts.This book does not pretend to be a replacement of the 2017 OECD Transfer Pricing Guidelines; it is an introduction, giving an overview of the wide variety of topics covered, with paragraph references to the underling Guideline paragraphs, so that we know where to find them. The original work can be bought from the OECD at http://www.oecd.org/tax/transfer-pricing/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-20769717.htm. For more information about me, please see my website (www.johannmuller.net), my YouTube channel, Taxpics (https://www.youtube.com/user/taxpics) and my LinkedIn profile (https://www.linkedin.com/in/johannhmuller).

Author : Johann H Müller
Publisher : Unknown
Page : 144 pages
File Size : 44,8 Mb
Release : 2020-03
Category : Electronic
ISBN : 9798620216802

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A Practical Summary of the 2017 OECD Transfer Pricing Guidelines by Johann H Müller Pdf

How many of us still have time to read 660+ page guidelines? How many of us have time to take those guidelines and combine them with chapters adopted after the guidelines were published? How does a student begin to study a work of this size, without getting hopelessly lost? This book reflects my love for systematic thinking and reducing clutter. It is aimed at giving fast, accurate, information through diagrams and summaries. I believe it may fill a need at a time where we are buried under information and do not always have time to read ten page articles, hundred-page court decisions, or six hundred page guidelines. This book does not pretend to be a replacement of the 2017 OECD Transfer Pricing Guidelines; it is an introduction, giving an overview of the wide variety of topics covered, with paragraph references to the underling Guideline paragraphs, so that we know where to find them. In this book, the 2017 OECD Transfer Pricing Guidelines are summarized three times: first as a one-page overview, then as a longer executive summary and finally as an extended summary of most of the paragraphs of the 2017 OECD Transfer Pricing Guidelines. The extended summary references the actual paragraphs in the 2017 OECD Transfer Pricing Guidelines. As the 2017 OECD Transfer Pricing Guidelines is a live document, which is continuously updated, I will substitute existing the 2017 OECD Transfer Pricing Guidelines chapters and paragraphs with draft and final material published after 2017. These texts are clearly marked and will first concern the profit allocation to PEs, the profit split method and financial transactions, when those documents are finalised by the OECD.The book follows the order of topics as given in the actual guidelines, albeit that I have added to Annexes to the different chapters in the chapters where they belong. This book is only descriptive: I have not given my opinion about the choices made, though it is difficult to make a summary without some degree of interpretation.

Author : Ioana Ignat,Liliana Ionescu-Feleagă
Publisher : Springer Nature
Page : 196 pages
File Size : 44,8 Mb
Release : 2022-05-09
Category : Business & Economics
ISBN : 9783030938895

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Transfer Pricing in Manufacturing by Ioana Ignat,Liliana Ionescu-Feleagă Pdf

Transfer pricing is considered a new and complex concept in terms of guidelines and regulations. In this context, more and more academics and tax professionals are interested in understanding the mechanism of a transfer pricing analysis. The main objective of the book is to help them in this process by presenting in a practical approach (using case studies and schemes) and in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations the way in which are operating the basic transfer pricing elements. Moreover, considering that the manufacturing sector is the chief wealth-producing sector of the global economy, the book illustrates complete transfer pricing analyses applicable for manufacturing transactions (using Orbis database). In the end, the book presents some recent disputes between manufacturing entities and tax authorities in relation to the transfer pricing analysis for manufacturing transactions. Chapter “TAMSAT” is available open access under a Creative Commons Attribution 4.0 International License via link.springer.com.

Author : OECD
Publisher : OECD Publishing
Page : 608 pages
File Size : 45,7 Mb
Release : 2017-07-10
Category : Electronic
ISBN : 9789264265127

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 by OECD Pdf

This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

Author : OECD
Publisher : OECD Publishing
Page : 372 pages
File Size : 47,6 Mb
Release : 2010-08-16
Category : Electronic
ISBN : 9789264090187

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010 by OECD Pdf

The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, the valuation, for tax purposes, of cross-border transactions between associated enterprises.

Author : OECD
Publisher : OECD Publishing
Page : 107 pages
File Size : 40,9 Mb
Release : 1979-06-01
Category : Electronic
ISBN : 9789264167773

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Transfer Pricing and Multinational Enterprises by OECD Pdf

The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.

Author : OECD
Publisher : OECD Publishing
Page : 659 pages
File Size : 50,8 Mb
Release : 2022-01-20
Category : Electronic
ISBN : 9789264921917

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 by OECD Pdf

In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.

Author : Veronika Solilova,Danuse Nerudova
Publisher : Springer
Page : 193 pages
File Size : 41,6 Mb
Release : 2017-10-31
Category : Business & Economics
ISBN : 9783319690650

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Transfer Pricing in SMEs by Veronika Solilova,Danuse Nerudova Pdf

This book provides a detailed assessment of current approaches to transfer pricing in the context of small- and middle-sized enterprises (SMEs), including the newest update of Transfer Pricing Guidelines from 10 July 2017. It analyzes the transfer pricing rules for SMEs across the European Union (EU) and explores two alternative approaches as suitable solutions for current transfer pricing issues. The authors evaluate and discuss alternative approaches like Safe Harbour and Common Consolidated Corporate Tax Base (CCCTB). Taking into account the prominent role of SMEs in the European Union’s economy, the book also puts forward policy recommendations to achieve the long-term goals of the EU’s 2020 agenda.

Author : Jerome Monsenego
Publisher : Kluwer Law International B.V.
Page : 281 pages
File Size : 45,6 Mb
Release : 2022-11-22
Category : Law
ISBN : 9789403514932

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Introduction to Transfer Pricing by Jerome Monsenego Pdf

Transfer pricing refers to the pricing of cross-border intercompany transactions. Transfer prices influence the tax base of multinational enterprises, and thus also the fiscal revenues of the countries where they are doing business. The importance of transfer pricing has significantly expanded over time and culminated with the work of the OECD on Base Erosion and Profit Shifting (BEPS). With the globalisation of business activities, the need for States to prevent tax avoidance, and the risk of double taxation faced by multinational enterprises, transfer pricing has become a key question for multinational enterprises and tax administrations alike. Introduction to Transfer Pricing intends at providing a general introduction to the fundamentals of transfer pricing. The book is focused on explanations of the principles that apply, albeit to various extents, in most countries. Although the majority of these principles are provided by the OECD the views of other international organisations – in particular the United Nations and the European Union – are also taken into account. Moreover, the book illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when conducting cross-border business activities. Also included are relevant court cases from a variety of countries. Among the issues and topics covered are the following: the arm’s length principle in theory and practice; transfer pricing methods; intercompany transactions involving intangibles and financial transactions; common types of transfer pricing models; cross-border business restructurings; the substance requirement for transfer pricing purposes; attribution of profits to permanent establishments; and the prevention and resolution of transfer pricing disputes. This second edition was updated based on the 2022 OECD Transfer Pricing Guidelines and the 2021 UN Transfer Pricing Manual.

Author : Organisation for Economic Co-operation and Development
Publisher : OECD
Page : 248 pages
File Size : 42,7 Mb
Release : 2009-09-15
Category : Business & Economics
ISBN : UCR:31210022611840

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 by Organisation for Economic Co-operation and Development Pdf

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.

Author : Organisation for Economic Co-operation and Development
Publisher : Organisation for Economic Co-operation and Development
Page : 76 pages
File Size : 44,6 Mb
Release : 1995
Category : International business enterprises
ISBN : UCSD:31822015194996

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Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations by Organisation for Economic Co-operation and Development Pdf

Includes 1999 update. 1998 update in back.

Author : United Nations
Publisher : Unknown
Page : 672 pages
File Size : 45,5 Mb
Release : 2017
Category : Business & Economics
ISBN : UIUC:30112116051332

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United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 by United Nations Pdf

The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.

Author : Steve Edge,Dominic Robertson
Publisher : Unknown
Page : 0 pages
File Size : 46,5 Mb
Release : 2023
Category : Electronic
ISBN : 1804491780

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The Transfer Pricing Law Review by Steve Edge,Dominic Robertson Pdf

Author : OECD
Publisher : OECD Publishing
Page : 44 pages
File Size : 42,5 Mb
Release : 2013-07-19
Category : Electronic
ISBN : 9789264202719

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Action Plan on Base Erosion and Profit Shifting by OECD Pdf

This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

Author : OECD
Publisher : OECD Publishing
Page : 100 pages
File Size : 40,5 Mb
Release : 2017-07-27
Category : Electronic
ISBN : 9789264278790

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OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS by OECD Pdf

This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).