International Transfer Pricing

Author : Wolfgang Schön,Kai A. Konrad
Publisher : Springer Science & Business Media
Page : 308 pages
File Size : 49,8 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 : Wagdy M. Abdallah
Publisher : Praeger
Page : 184 pages
File Size : 53,5 Mb
Release : 1989-03-13
Category : Business & Economics
ISBN : UCSD:31822003998440

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International Transfer Pricing Policies by Wagdy M. Abdallah Pdf

"In this valuable work Professor Abdallah lays out the factors a good international transfer pricing system should have. . . . A multinational enterprise must reach a number of business decisions involving transfer pricing, such as where to manufacture a specific product, levels of capital investment, and profit planning by location. Rather than shooting from the hip' and trying to solve problems one at a time, Professor Abdallah says, companies should develop a comprehensive policy to resolve the inevitable problems. In short, transfer pricing problems are here and will continue to be here. While there is no single answer, a written policy approach is best. Anyone responsible for international transfer pricing will be helped immeasurably by referring to this valuable book." Management Accounting

Author : Geoff Turner
Publisher : Business Expert Press
Page : 114 pages
File Size : 50,6 Mb
Release : 2013-03-15
Category : Business & Economics
ISBN : 9781606493496

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Transfer Pricing in International Business by Geoff Turner Pdf

For centuries, trade has endured stumbling blocks, mistakes, and moments of inspiration. It has contributed to the modern, globalized world in which we live, and the increasing economic, social, and political importance of trade has spawned a phenomenon called the multinational organization. However, these organizations have a national home to where profits will ultimately have to come, and in their effort to maximize the amount repatriated, they often engage in internal-pricing practices, known more commonly as transfer pricing This book reminds us all of the important issues of transfer pricing, and how easy it is to create friction between all of the interested parties. This book also goes on to provide an insight into how such conflicts can be assuaged or avoided altogether, and explains how transfer pricing may become a managerial tool by establishing a common language that may be used as one driver for creating added value throughout the organization. Transfer pricing is not simply about maximizing income. It is a much more important strategic management issue that, treated unwisely or with ignorance, is likely to lead to an incongruity in the added value of an organization’s products and services as well as its crucial return on capital employed.

Author : Michael Lang,Giammarco Cotani,Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
Page : 484 pages
File Size : 49,5 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 : 608 pages
File Size : 51,6 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 : 659 pages
File Size : 41,6 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 : Anonim
Publisher : Unknown
Page : 354 pages
File Size : 47,7 Mb
Release : 1991
Category : Electronic
ISBN : OCLC:834206337

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International Transfer Pricing by Anonim Pdf

Author : A. Michael Heimert,Michelle Johnson (Economist),Duff & Phelps Corp
Publisher : Unknown
Page : 0 pages
File Size : 41,7 Mb
Release : 2013
Category : International business enterprises
ISBN : 9041138978

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Guide to International Transfer Pricing by A. Michael Heimert,Michelle Johnson (Economist),Duff & Phelps Corp Pdf

"The pricing of goods and services within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of tax revenue overseas, making the issue one of great importance to multinational corporations. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide's relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions."

Author : Jens Wittendorff
Publisher : Kluwer Law International B.V.
Page : 914 pages
File Size : 46,6 Mb
Release : 2010-01-01
Category : Law
ISBN : 9789041132703

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Transfer Pricing and the Arm's Length Principle in International Tax Law by Jens Wittendorff Pdf

The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.

Author : Andrew Lymer,John Hasseldine
Publisher : Springer Science & Business Media
Page : 319 pages
File Size : 50,5 Mb
Release : 2012-12-06
Category : Business & Economics
ISBN : 9781461510710

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The International Taxation System by Andrew Lymer,John Hasseldine Pdf

International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.

Author : J. Li
Publisher : Springer
Page : 265 pages
File Size : 53,5 Mb
Release : 2005-09-08
Category : Business & Economics
ISBN : 9780230511606

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International Transfer Pricing in Asia Pacific by J. Li Pdf

In the management of business activity by companies operating in more than one country, the complex array of issues and practices that characterize their movements of assets between constituent company units centres around what has become known as international transfer payments. This book, based on extensive research, explains the nature of the subject, presents the latest data on the practice of transfer payments in three Asia Pacific countries; the regulations, attitudes and conditions which form the context in which they take place; and the events which are most likely to precipitate the intervention of the authorities and lead to investigation and audit.

Author : Mark Atkinson,David Tyrrall
Publisher : Ft Press
Page : 284 pages
File Size : 54,8 Mb
Release : 1999
Category : Business & Economics
ISBN : 0273638106

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International Transfer Pricing by Mark Atkinson,David Tyrrall Pdf

The rules applying to international transfer pricing are changing radically. Failure to comply could lead to severe tax penalties, whilst planning now will save you time and money. What are the implications of the new legislation and how can you comply? International Transfer Pricing offers you the essential guidance you need on planning an effective Transfer Pricing strategy. This report explains the implications of the changes in legislation for multinational companies and details what you can do now to prepare. If your company operates in a multinational environment, then this report will be of practical relevance to you.

Author : Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra
Publisher : World Bank Publications
Page : 388 pages
File Size : 46,8 Mb
Release : 2017-01-05
Category : Business & Economics
ISBN : 9781464809705

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Transfer Pricing and Developing Economies by Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra Pdf

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 : Raffaele Petruzzi,Romero J.S. Tavares Esq.
Publisher : Linde Verlag GmbH
Page : 472 pages
File Size : 50,6 Mb
Release : 2019-09-02
Category : Law
ISBN : 9783709410387

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Transfer Pricing and Value Creation by Raffaele Petruzzi,Romero J.S. Tavares Esq. Pdf

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 : Robert Robillard
Publisher : Self-Counsel Press
Page : 131 pages
File Size : 47,8 Mb
Release : 2020-09-15
Category : Business & Economics
ISBN : 9781770405189

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Transfer Pricing in Canada and the United States by Robert Robillard Pdf

In this day and age, international expansion or simply conducting commercial dealings across borders, without too many hassles, is a taxing proposal. Without a strong understanding of the laws ruling international taxes, peace of mind is, at best, elusive. This book focuses on the rules of transfer pricing within the international tax regime, as they stand in Canada and the United States. Commercial enterprises large and small will benefit from the expert advice in this book. Author Robert Robillard brings his years of experience as an economist, accountant, and teacher to this work. He explains the background of pricing cross-border transactions between related parties, and offers a “Transfer Pricing Tool Kit” for the design, implementation, and documentation of the value chain for business and taxation purposes. Robillard covers the expected and unexpected relationships that will emerge from the cross-border transactions: the transfer pricing audit and the mechanisms available to remedy double taxation, as well as the usefulness of an advisor with respect to the handling of cross-border transactions.