An Analysis Of Adequate Oecd Transfer Pricing Methods For Intangible Property

Author : Melanie Keller
Publisher : GRIN Verlag
Page : 32 pages
File Size : 43,7 Mb
Release : 2015-07-24
Category : Business & Economics
ISBN : 9783668021938

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An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property by Melanie Keller Pdf

Bachelor Thesis from the year 2015 in the subject Economics - International Economic Relations, Management Center Innsbruck, language: English, abstract: Due to increased globalisation over the last years and enhanced activities of multinational enterprises (MNEs), intra-firm trade has become more and more important. Intra-firm trade is estimated to constitute about one third of the global trade; and about 50% of all exports within the member states of the Organisation for Economic Co-operation and Development (OECD) are intra-firm exports. In order to determine the expenses and revenues for the associated companies, transfer prices (TP) have to be set for the respective goods of intra-group transfers (Organisation for Economic Co-operation and Development [OECD]). Intra-group transfers can be defined as the transaction of tangible or intangible property from one entity of a MNE to another entity, considered as sale and “may apply to departments, divisions, subsidiaries, or affiliate business units” . A TP therefore is the internal monetary value im-posed on goods, services or unmanufactured material that is transferred within a MNE group. According to the OECD (2010) intra-firm transfers are likewise de-fined as controlled transactions (i.e., transactions between two associated enterprises).

Author : OECD
Publisher : OECD Publishing
Page : 132 pages
File Size : 52,9 Mb
Release : 2014-09-16
Category : Electronic
ISBN : 9789264219212

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OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Aspects of Intangibles by OECD Pdf

This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles.

Author : OECD
Publisher : OECD Publishing
Page : 107 pages
File Size : 49,6 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 : Michelle Markham
Publisher : Kluwer Law International B.V.
Page : 360 pages
File Size : 52,7 Mb
Release : 2005-01-01
Category : Law
ISBN : 9789041123688

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The Transfer Pricing of Intangibles by Michelle Markham Pdf

Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.

Author : OECD
Publisher : OECD Publishing
Page : 372 pages
File Size : 52,6 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 : Michael Lang,Alfred Storck,Raffaele Petruzzi,Robert Risse
Publisher : Linde Verlag GmbH
Page : 176 pages
File Size : 45,6 Mb
Release : 2019-04-11
Category : Law
ISBN : 9783709410103

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Transfer Pricing and Intangibles by Michael Lang,Alfred Storck,Raffaele Petruzzi,Robert Risse Pdf

Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.

Author : OECD
Publisher : OECD Publishing
Page : 247 pages
File Size : 43,9 Mb
Release : 2009-08-18
Category : Electronic
ISBN : 9789264075344

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 by OECD 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 : OECD
Publisher : OECD Publishing
Page : 216 pages
File Size : 45,6 Mb
Release : 2017-07-31
Category : Electronic
ISBN : 9789264279971

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

Author : Ioana Ignat,Liliana Ionescu-Feleagă
Publisher : Springer Nature
Page : 196 pages
File Size : 55,6 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 : Robert Feinschreiber
Publisher : John Wiley & Sons
Page : 1040 pages
File Size : 54,5 Mb
Release : 2001
Category : Comparative law
ISBN : STANFORD:36105060784365

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Transfer Pricing Handbook by Robert Feinschreiber Pdf

This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).

Author : Michael Lang,Giammarco Cotani,Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
Page : 484 pages
File Size : 46,7 Mb
Release : 2021-06-18
Category : Law
ISBN : 9789403517247

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Fundamentals of Transfer Pricing by Michael Lang,Giammarco Cotani,Raffaele Petruzzi Pdf

Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.

Author : OECD
Publisher : OECD Publishing
Page : 263 pages
File Size : 44,6 Mb
Release : 1999-11-12
Category : Electronic
ISBN : 9789264187757

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Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations SET Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations - Binder+1999 Update by OECD Pdf

Author : Wolfgang Schön,Kai A. Konrad
Publisher : Springer Science & Business Media
Page : 308 pages
File Size : 51,6 Mb
Release : 2012-02-15
Category : Law
ISBN : 9783642259807

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Fundamentals of International Transfer Pricing in Law and Economics by Wolfgang Schön,Kai A. Konrad Pdf

The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.

Author : Monica Boos
Publisher : Unknown
Page : 288 pages
File Size : 44,5 Mb
Release : 2003
Category : Business & Economics
ISBN : IND:30000094764135

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International Transfer Pricing by Monica Boos Pdf

The valuation of intangibles as they are transferred from country to country but within multinational enterprise networks is major issue in taxation.

Author : OECD
Publisher : OECD Publishing
Page : 157 pages
File Size : 47,5 Mb
Release : 2005-05-12
Category : Electronic
ISBN : 9789264007222

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OECD Tax Policy Studies E-commerce: Transfer Pricing and Business Profits Taxation by OECD Pdf

The increased speed and mobility of business activities and cross-border transactions resulting from internet usage has particular implications for applying transfer pricing methods and for taxing business profits. This book presents a two-part look at existing OECD positions on these issues.