International Transfer Pricing In Asia Pacific

Author : J. Li
Publisher : Springer
Page : 265 pages
File Size : 41,9 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 : Robert Feinschreiber,Margaret Kent
Publisher : John Wiley & Sons
Page : 558 pages
File Size : 51,5 Mb
Release : 2012-10-03
Category : Business & Economics
ISBN : 9781118359402

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Asia-Pacific Transfer Pricing Handbook by Robert Feinschreiber,Margaret Kent Pdf

An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businesses A comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders. Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad. Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the law A complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad.

Author : International Bureau of Fiscal Documentation. IBFD,Organisation for Economic Co-operation and Development. OECD
Publisher : Unknown
Page : 768 pages
File Size : 50,7 Mb
Release : 2014
Category : International business enterprises
ISBN : 9087222521

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2010 Edition) and Transfer Pricing Features of Selected Countries, 2014 by International Bureau of Fiscal Documentation. IBFD,Organisation for Economic Co-operation and Development. OECD Pdf

The increase in global trade and foreign direct investment has seen a large rise in companies operating across national borders. The growth of these multinational companies (MNCs) has been closely followed by the issue of inter-company transfer prices being used to reduce taxable profits. Today, transfer pricing is one of the most important issues facing MNCs as they attempt to fairly distribute their profits amongst each company in the group while dealing with tax authorities who are implementing transfer pricing regulations and strengthening enforcement in order to prevent a loss of revenue. The result of which is that transfer pricing controversies have become a major tax issue for companies.

Author : Kenneth R. L. Parker
Publisher : Gbis, Incorporated
Page : 247 pages
File Size : 53,8 Mb
Release : 2010
Category : Transfer pricing
ISBN : 1602310084

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Tax Director's Guide to Transfer Pricing in Asia and Australia by Kenneth R. L. Parker Pdf

A dozen leading transfer pricing professionals from Baker & McKenzie, Deloitte, Ernst & Young, KPMG and PricewaterhouseCoopers offer their advice and insights on how to navigate complex issues in Australia, China, Hong Kong, India, Japan, and Singapore. Topics discussed include: application of safe harbor provisions in Australia, understanding Japan's new documentation requirements, strategies to minimize transfer pricing risk in India, implications of recent court decisions in Hong Kong, valuing intra-group services in Singapore, and how to apply the Best Method Rule in China. The book includes English translations of China and Japan's implementing regulations, and overview of the transfer pricing analysis process, and a glossary of transfer pricing terminology.

Author : Yong Sup Sim,Mei-June Soo
Publisher : Unknown
Page : 678 pages
File Size : 47,8 Mb
Release : 2017
Category : BEPS.
ISBN : 9087224176

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Asian Voices by Yong Sup Sim,Mei-June Soo Pdf

The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project has, thus far, mostly been an OECD-driven project. Nevertheless, its efforts in involving representatives from developing and emerging countries in the Asia-Pacific region have been encouraging and are laudable, given the tremendous challenges of achieving global consensus in a highly technical field and the tight time frame of the BEPS Project. The Asia-Pacific region poses unique challenges in its great diversity of economic development, as well as cultural and legal traditions. Australia, Japan, New Zealand and Korea, as OECD members, are at the forefront of tax innovation and development, while China, India and Indonesia are at the table as members of the G20. However, the majority of the countries in the region are non-OECD, non-G20 developing countries. For these developing countries, the BEPS changes will bring added challenges at a time when their economies are rapidly transforming and they are in the midst of absorbing and legislating pre-existing international tax principles and modernizing their tax administration --Back cover.

Author : Anonim
Publisher : Unknown
Page : 354 pages
File Size : 54,7 Mb
Release : 1991
Category : Electronic
ISBN : OCLC:834206337

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International Transfer Pricing by Anonim Pdf

Author : Eduardo Baistrocchi,Ian Roxan
Publisher : Cambridge University Press
Page : 975 pages
File Size : 45,5 Mb
Release : 2012-12-06
Category : Law
ISBN : 9781139916288

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Resolving Transfer Pricing Disputes by Eduardo Baistrocchi,Ian Roxan Pdf

Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

Author : Dr A. Michael Heimert,T.J. Michaelson
Publisher : Kluwer Law International B.V.
Page : 1290 pages
File Size : 55,5 Mb
Release : 2018-10-26
Category : Law
ISBN : 9789403501710

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Guide to International Transfer Pricing by Dr A. Michael Heimert,T.J. Michaelson Pdf

The pricing of goods, services, intangible property and financial instruments 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 their tax revenue from their jurisdictions. 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 : Alan Paisey,Jian Li
Publisher : Universal-Publishers
Page : 152 pages
File Size : 52,8 Mb
Release : 2012
Category : Business & Economics
ISBN : 9781612335490

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Transfer Pricing by Alan Paisey,Jian Li Pdf

This book offers an introduction to transfer pricing with particular reference to China, for those who are looking for an overview that can be rapidly comprehended and who value diagrammatic images as a vehicle for learning. The subject is of importance both for Chinese and foreign personnel engaged in foreign company activity in China and for those who are similarly engaged in Chinese-owned companies already operating abroad, or which are to be extended to foreign locations.

Author : J. Li,A. Paisey
Publisher : Springer
Page : 185 pages
File Size : 42,8 Mb
Release : 2007-01-10
Category : Business & Economics
ISBN : 9780230595811

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Transfer Pricing Audits in China by J. Li,A. Paisey Pdf

This book focuses on the practice of transfer pricing audits which the Chinese government operates in the case of the vast number of foreign enterprises operating in the Chinese economy. It includes the testimony of Chinese officials about their work, material that given the secrecy of Chinese business and culture, is difficult to come by.

Author : Judy S. Kuan
Publisher : WorldTrade Executive, Inc.
Page : 346 pages
File Size : 51,8 Mb
Release : 2004-11
Category : Business & Economics
ISBN : 1893323668

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Global Transfer Pricing Solutions by Judy S. Kuan Pdf

GLOBAL TRANSFER PRICING SOLUTIONS: 2004 covers the major transfer pricing regimes around the world with in-depth discussion and analysis of such topics as proactive transfer pricing management of post-merger integrations, e-commerce and intellectual property. This report was prepared by members of major law and accounting firms and senior international transfer pricing professionals at the largest multinationals. It covers a wide range of tools and techniques relevant to transfer pricing in Asia, Europe, Latin America, and North America.

Author : Wagdy M. Abdallah
Publisher : Bloomsbury Publishing USA
Page : 272 pages
File Size : 40,6 Mb
Release : 2004-07-30
Category : Business & Economics
ISBN : 9780313053689

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Critical Concerns in Transfer Pricing and Practice by Wagdy M. Abdallah Pdf

For multinational corporations (MNCs), there is arguably no more important operational function that affects all areas of manufacturing, marketing, management, and finance as international transfer pricing—the practicing of supplying products or services across borders from one part of the organization to another. Its complexity is compounded by the impact of e-commerce, speeding the flow of goods and services; intangible assets, such as intellectual property, whose value is difficult to quantify; and the activites of policymakers around the world to update their tax laws and regulations, in efforts to close loopholes that have historically encouraged tax avoidance. In Critical Concerns in Transfer Pricing Policy and Practice, Wagdy Abdallah provides an in-depth overview of these recent trends and developments, and considers their implications for the management of MNCs. In particular, he discusses methods for pricing transferred goods and services in the e-commerce era and analyzes the most recent regulation reforms in such countries as Germany, Mexico, Japan, Canada, the United Kingdom, the United States, and the Netherlands. Anticipating increased scrutiny of MNC transfer pricing practices from governments and other external stakeholders, Abdallah outlines a set of practical recommendations for creating a successful transfer pricing system that maximizes value for the company while remaining sensitive to local policies in all of the countries in which it operates.

Author : Raffaele Petruzzi,Michael Lang
Publisher : Kluwer Law International B.V.
Page : 261 pages
File Size : 45,8 Mb
Release : 2023-03-09
Category : Law
ISBN : 9789403540337

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Transfer Pricing and Financing by Raffaele Petruzzi,Michael Lang Pdf

In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions: loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law. Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.

Author : Jian Li,Alan Paisey
Publisher : Springer
Page : 192 pages
File Size : 42,5 Mb
Release : 2019-05-30
Category : Business & Economics
ISBN : 9789811376894

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Transfer Pricing in China by Jian Li,Alan Paisey Pdf

This book offers up to date insights into the exciting world of China’s extensive economic activity through the pervasive and often secretive practice of transfer pricing. It begins with an explanation of transfer pricing itself and goes on to explore how intricately it can infiltrate the trading practices of the commercial lives of both foreign companies in China and Chinese companies expanding to other countries. A review of the main industries in China also considers their possible future uncertainties. China has joined other authorities in actively legislating and organizing a regime to implement its arm’s length policy, as related in Part I of the book on concepts and controls. This is then followed by Part 2 which is devoted to a collection of cases showing the breadth and variability of companies actively seeking to maximise their profits, while Part 3 of the book gives a rare record of the order of priorities exercised by one hundred Chinese tax officers engaged in auditing company performance. The book ends with a summary of the future trends, and activities that regulatory authorities are likely to undertake.

Author : Jerome Monsenego
Publisher : Kluwer Law International B.V.
Page : 281 pages
File Size : 41,9 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.