Introduction To Transfer Pricing

Author : Jerome Monsenego
Publisher : Kluwer Law International B.V.
Page : 281 pages
File Size : 47,6 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 : Jerome Monsenego
Publisher : Unknown
Page : 163 pages
File Size : 46,9 Mb
Release : 2013-01-01
Category : Business & Economics
ISBN : 9144092709

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Introduction to Transfer Pricing by Jerome Monsenego Pdf

Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.

Author : Oliver Treidler
Publisher : Springer Nature
Page : 145 pages
File Size : 51,6 Mb
Release : 2019-09-12
Category : Business & Economics
ISBN : 9783030250850

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Transfer Pricing in One Lesson by Oliver Treidler Pdf

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 : Michael Lang,Giammarco Cotani,Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
Page : 484 pages
File Size : 44,9 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 : Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck
Publisher : Kluwer Law International B.V.
Page : 500 pages
File Size : 52,7 Mb
Release : 2019-01-03
Category : Law
ISBN : 9789041190215

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Fundamentals of Transfer Pricing by Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck Pdf

Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.

Author : Centre on Transnational Corporations (United Nations)
Publisher : New York : United Nations
Page : 124 pages
File Size : 44,5 Mb
Release : 1988
Category : Business & Economics
ISBN : UOM:39015024913652

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International Income Taxation and Developing Countries by Centre on Transnational Corporations (United Nations) Pdf

Study on the income tax structure applicable to multinational companies operating in developing countries with reference to double taxation treaties and transfer pricing problems.

Author : Alan Paisey,Jian Li
Publisher : Universal-Publishers
Page : 152 pages
File Size : 51,5 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 : Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck
Publisher : Unknown
Page : 0 pages
File Size : 53,8 Mb
Release : 2019
Category : International business enterprises
ISBN : 9041189947

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Fundamentals of Transfer Pricing by Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck Pdf

Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P - Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. In analysing the topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding.

Author : Raffaele Petruzzi,Giammarco Cottani,Michael Lang
Publisher : Kluwer Law International B.V.
Page : 549 pages
File Size : 50,9 Mb
Release : 2022-06-20
Category : Law
ISBN : 9789403535203

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

This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing’s interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.

Author : Oliver Treidler
Publisher : Unknown
Page : 138 pages
File Size : 41,6 Mb
Release : 2020
Category : Accounting
ISBN : 3030250865

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Transfer Pricing in One Lesson by Oliver Treidler Pdf

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 : OECD
Publisher : OECD Publishing
Page : 608 pages
File Size : 48,9 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 : Marc M. Levey,Steven C. Wrappe,Kerwin Chung
Publisher : CCH
Page : 232 pages
File Size : 49,5 Mb
Release : 2006
Category : Business & Economics
ISBN : 0808015532

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Transfer Pricing Rules and Compliance Handbook by Marc M. Levey,Steven C. Wrappe,Kerwin Chung Pdf

This book gives an overview of the basic principles of transfer pricing and U.S. transfer pricing rules, and the impact of transfer pricing on other issues such as customs valuation, Section 404 of the Sarbanes-Oxley Act of 2002, and FASB Interpretation no. 48.

Author : Aydin Hayri,Althea Azeff
Publisher : Kluwer Law International
Page : 0 pages
File Size : 51,6 Mb
Release : 2013
Category : Transfer pricing
ISBN : 9041146857

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Transfer Pricing in Action by Aydin Hayri,Althea Azeff Pdf

This book provides an overview of the abstract theory of transfer pricing and its everyday practice. It is an extended hypothetical case history, presented in narrative style illustrated with graphics. It gives details of transfer pricing planning and how the process engages and affects the ambitions, insights, and interactions of the group of business people and advisors involved. The book contains the following chapters: (1) MSell - a fast growth company considers corporate taxation; (2) Big tax proposal, rejected; (3) The inevitable growing pains, and state tax planning ; (4) Going international, the Canadian expansion; (5) Further expansion: the United Kingdom and greater Europe; (6) The European distributors and a surprising development, or two; (7) Services transactions: US headquarter and support services for Europe; (8) Intangibles licensing transaction, with gusto; (9) Intra-European structuring; (10) Sourcing; (11) Branding, and a new CEO; (12) Planning for a new global business model; (13) Designing and implementing the new global business model; (14) A (rather unpleasant) Thanksgiving surprise; and a timeline figure.

Author : Jean-Pierre Vidal,Marie-Pierre Allard,Cindy Harvey,Julie Robson,Marwah Rizqy
Publisher : Unknown
Page : 128 pages
File Size : 51,9 Mb
Release : 2018-08
Category : Electronic
ISBN : 0779883322

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Introduction to International Tax in Canada by Jean-Pierre Vidal,Marie-Pierre Allard,Cindy Harvey,Julie Robson,Marwah Rizqy Pdf

Author : OECD
Publisher : OECD Publishing
Page : 659 pages
File Size : 43,7 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.