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Author : OECD
Publisher : OECD Publishing
Page : 110 pages
File Size : 45,7 Mb
Release : 2012-01-18
Category : Electronic
ISBN : 9789264169463
This report addresses the practical administration of transfer pricing programmes by tax administrations.
Author : OECD
Publisher : OECD Publishing
Page : 106 pages
File Size : 41,9 Mb
Release : 2012-02-06
Category : Electronic
ISBN : 9264169075
This report addresses the practical administration of transfer pricing programmes by tax administrations.
Author : Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra
Publisher : World Bank Publications
Page : 388 pages
File Size : 46,5 Mb
Release : 2017-01-05
Category : Business & Economics
ISBN : 9781464809705
Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.
Author : Andrea Musselli
Publisher : Gruppo 24 Ore
Page : 446 pages
File Size : 52,8 Mb
Release : 2022-09-15T00:00:00+02:00
Category : Business & Economics
ISBN : 9791254831540
The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.
Author : Raffaele Petruzzi,Romero J.S. Tavares Esq.
Publisher : Linde Verlag GmbH
Page : 572 pages
File Size : 47,5 Mb
Release : 2019-09-02
Category : Law
ISBN : 9783709410370
Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Author : Philip Daniel,Michael Keen,Artur Świstak,Victor Thuronyi
Publisher : Routledge
Page : 382 pages
File Size : 52,5 Mb
Release : 2016-09-23
Category : Business & Economics
ISBN : 9781317330134
The taxation of extractive industries exploiting oil, gas, or minerals is usually treated as a sovereign, national policy and administration issue. This book offers a uniquely comprehensive overview of the theory and practice involved in designing policies on the international aspects of fiscal regimes for these industries, with a particular focus on developing and emerging economies. International Taxation and the Extractive Industries addresses key topics that are not frequently covered in the literature, such as the geo-political implications of cross-border pipelines and the legal implications of mining contracts and regional financial obligations. The contributors, all of whom are leading researchers with experience of working with governments and companies on these issues, present an authoritative collection of chapters. The volume reviews international tax rules, covering both developments in the G20-OECD project on ’Base Erosion and Profit Shifting’ and more radical proposals, identifying core challenges in the extractives sector. This book should become a core resource for both scholars and practitioners. It will also appeal to those interested in international tax issues more widely and those who study environmental economics, macroeconomics and development economics.
Author : Ekkehart Reimert,Alexander Rust
Publisher : Kluwer Law International B.V.
Page : 3112 pages
File Size : 51,9 Mb
Release : 2022-01-18
Category : Law
ISBN : 9789403512846
Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University
Author : Cheryl S. McWatters,Jerold L. Zimmerman
Publisher : Routledge
Page : 732 pages
File Size : 43,5 Mb
Release : 2015-12-22
Category : Business & Economics
ISBN : 9781135039394
Whether students pursue a professional career in accounting or in other areas of management, they will interact with accounting systems. In all organizations, managers rely on management accounting systems to provide information to deal with changes in their operating environment. This book provides students and managers with an understanding and appreciation of the strengths and limitations of an organization’s accounting system, and enables them to be intelligent and critical users of the system. The text highlights the role of management accounting as an integral part of the organization’s strategy and not merely a set of individual concepts and computations. An analytical framework for organizational change is used throughout the book to underscore how organizations must adapt to create customer and organizational value. This framework provides a way to examine and analyze the organization’s accounting system, and as a basis for evaluating proposed changes to the system. With international examples that bring the current business environment to the forefront, problems and cases to promote critical thinking, and online support for students and instructors, Management Accounting in a Dynamic Environment is no mere introductory textbook. It prepares readers to use accounting systems intelligently to achieve organizational success. The authors have identified several cases to accompany each chapter in the textbook. These are available through Ivey Publishing: https://www.iveycases.com/CaseMateBookDetail.aspx?id=434
Author : OECD,United Nations Economic Commission for Africa
Publisher : OECD Publishing
Page : 70 pages
File Size : 53,5 Mb
Release : 2012-05-10
Category : Electronic
ISBN : 9789264255616
The Mutual Review of Development Effectiveness is an exercise in mutual accountability undertaken jointly by the UNECA and the OECD following a request of NEPAD Heads of State and Government in 2003.
Author : OECD
Publisher : OECD Publishing
Page : 128 pages
File Size : 51,6 Mb
Release : 2014-04-23
Category : Electronic
ISBN : 9789264203501
This publication identifies the main areas of weakness and potential areas for action to combat money-laundering, tax evasion, foreign bribery, and to identify, freeze and return stolen assets.
Author : OECD
Publisher : OECD Publishing
Page : 81 pages
File Size : 45,8 Mb
Release : 2012-11-19
Category : Electronic
ISBN : 9789264175464
In this report, released in May at the annual meeting of the OECD Council at ministerial level, the Secretary-General summarises the activities of the OECD during the previous year.
Author : Frederick M. Abbott,Carlos M. Correa,Peter Drahos
Publisher : Edward Elgar Publishing
Page : 439 pages
File Size : 50,6 Mb
Release : 2013-12-27
Category : Law
ISBN : 9781783471256
The patent has emerged as a dominant force in 21st century economic policy. This book examines the impact of the BRICS and other emerging economies on the global patent framework and charts the phenomenal rise in the number of patents in some of these cou
Author : Andreas Klasen
Publisher : John Wiley & Sons
Page : 624 pages
File Size : 47,7 Mb
Release : 2020-02-03
Category : Political Science
ISBN : 9781119167389
Provides a state-of-the-art overview of international trade policy research The Handbook of Global Trade Policy offers readers a comprehensive resource for the study of international trade policy, governance, and financing. This timely and authoritative work presents contributions from a team of prominent experts that assess the policy implications of recent academic research on the subject. Discussions of contemporary research in fields such as economics, international business, international relations, law, and global politics help readers develop an expansive, interdisciplinary knowledge of 21st century foreign trade. Accessible for students, yet relevant for practitioners and researchers, this book expertly guides readers through essential literature in the field while highlighting new connections between social science research and global policy-making. Authoritative chapters address new realities of the global trade environment, global governance and international institutions, multilateral trade agreements, regional trade in developing countries, value chains in the Pacific Rim, and more. Designed to provide a well-rounded survey of the subject, this book covers financing trade such as export credit arrangements in developing economies, export insurance markets, climate finance, and recent initiatives of the World Trade Organization (WTO). This state-of-the-art overview: Integrates new data and up-to-date research in the field Offers an interdisciplinary approach to examining global trade policy Introduces fundamental concepts of global trade in an understandable style Combines contemporary economic, legal, financial, and policy topics Presents a wide range of perspectives on current issues surrounding trade practices and policies The Handbook of Global Trade Policy is a valuable resource for students, professionals, academics, researchers, and policy-makers in all areas of international trade, economics, business, and finance.
Author : Oliver Treidler
Publisher : Springer Nature
Page : 145 pages
File Size : 51,8 Mb
Release : 2019-09-12
Category : Business & Economics
ISBN : 9783030250850
This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm’s length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book’s content is applicable to a global context.
Author : Patricia Adam
Publisher : UTB
Page : 370 pages
File Size : 42,7 Mb
Release : 2015-06-17
Category : Business & Economics
ISBN : 9783825286163
“Managing Internationalisation” explains the process of internationalising any kind of organisation from a management perspective. Based on the renowned EFQM Excellence Model, all issues with special relevance for international activities are explained and traced back to recent scientific research and good management practise. The book is meant for practitioners and students alike. For a better understanding, extensive illustrations, examples, exercises and recommendations for case studies enrich the text. Dieses Buch erklärt den Prozess der Internationalisierung von Organisationen aus der Sicht des Managements. Auf der Basis des EFQM-Modells für Business Excellence (Qualitätsmanagement) werden alle für internationale Aktivitäten relevanten Themen erläutert. Das Buch ist für Praktiker und Studierende gleichermaßen geeignet. Mit praxisnahen Übungen und Fallstudien.
