Tax Director S Guide To International Transfer Pricing 2010 Edition

Author : Brian E. Andreoli,Marc M. Levey
Publisher : Gbis, Incorporated
Page : 560 pages
File Size : 43,5 Mb
Release : 2010-06
Category : Business & Economics
ISBN : 1602310041

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Tax Director's Guide to International Transfer Pricing: 2010 Edition by Brian E. Andreoli,Marc M. Levey Pdf

More than fifty of the world's leading transfer pricing professionals offer their advice and insights on how to navigate complex issues, including: When is an APA Advantageous?, Understanding the New U.S. Services Regulations, Transfer Pricing Implications of Reorganizations, Valuing Intangibles Under Cost Sharing Arrangements, and How to Apply the Best Method Rule. The book also provides a country-by-country review of transfer pricing laws in seventeen major economies, addressing questions such as: What transfer pricing methods are accepted?, Do the local tax authorities favor a given method?, What dispute resolution mechanisms are available?, Are APAs allowed and, if so, what are the rules, To what extent are international guidelines followed?, How is the acceptability of comparables determined?, What are the documentation requirements?, and How are non-compliance penalties calculated? This newly updated 2010 Edition builds on the success of the original Tax Director's Guide to International Transfer Pricing, which has been relied upon by international tax professionals around the world. The articles in this new edition reflect the intense competition for tax dollars among various countries in a time of global recession, during which many tightened their transfer pricing rules and increased enforcement. The majority of the articles contain significant substantive updates. In addition, the book includes five new country overview articles discussing transfer pricing rules and practices in Australia, Hong Kong, India, Japan, and Singapore. This edition also includes an entirely new China section in response to the major transfer pricing legislation that recently went into effect, as well as a new article on supply chain management. In-house tax specialists and outside advisors alike will find this book to be an invaluable resource in their efforts to manage global tax exposure.

Author : Brian E. Andreoli,Marc M. Levey
Publisher : Gbis, Incorporated
Page : 404 pages
File Size : 50,5 Mb
Release : 2008
Category : Business & Economics
ISBN : 1602310017

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Tax Director's Guide to International Transfer Pricing by Brian E. Andreoli,Marc M. Levey Pdf

Forty-two of the world's leading transfer pricing professionals offer their advice and insights on how to navigate complex issues, and provide a country-by-country review of transfer pricing laws in a dozen major economies.

Author : Kenneth R. L. Parker
Publisher : Gbis, Incorporated
Page : 247 pages
File Size : 40,8 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 : A. Michael Heimert,Michelle Johnson (Economist),Duff & Phelps Corp
Publisher : Unknown
Page : 0 pages
File Size : 44,9 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 : Duff & Phelps
Publisher : Kluwer Law International
Page : 0 pages
File Size : 40,5 Mb
Release : 2017
Category : International business enterprises
ISBN : 904119049X

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Guide to International Transfer Pricing by Duff & Phelps Pdf

"In this book, global practitioners address both the general issues that surround transfer pricing, including the OECD's fifteen-item base erosion and profit shifting plan and the specific rules and issues that any company must concern itself with in various jurisdictions around the world. Tax authorities around the globe are increasingly scrutinizing the intercompany pricing practices of taxpayers and enacting rules and regulations to ensure an appropriate allocation of income among the various tax jurisdictions in which a multinational company operates. In addition, a growing number of tax authorities have established documentation requirements to demonstrate appropriate transfer pricing policies, with penalty provisions for non-compliance."--

Author : Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck
Publisher : Kluwer Law International B.V.
Page : 500 pages
File Size : 55,7 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 : Ceteris
Publisher : Unknown
Page : 0 pages
File Size : 49,7 Mb
Release : 2012
Category : International business enterprises
ISBN : 9041136592

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Guide to International Transfer Pricing by Ceteris Pdf

Also available online at www.kluwerlawonline.com 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 11 country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.

Author : Robert Feinschreiber
Publisher : Unknown
Page : 0 pages
File Size : 45,8 Mb
Release : 2000
Category : Comparative law
ISBN : OCLC:1336446818

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Transfer Pricing International by Robert Feinschreiber Pdf

Author : Robert Feinschreiber
Publisher : John Wiley & Sons
Page : 338 pages
File Size : 53,8 Mb
Release : 2004-03-01
Category : Business & Economics
ISBN : 9780471651239

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Transfer Pricing Methods by Robert Feinschreiber Pdf

Advanced praise for Transfer Pricing Methods "Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue." -Charles R. Goulding, Managing Director, Tax Cooper Industries, Inc. "It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses." -Vikram A. Gosain, JD, CPA, Director of Transfer Pricing General Electric Capital Corporation "This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants." -Joseph C. Mandarino, Partner Troutman Sanders, LLP "Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty." -Charles L. Crowley, Partner ITS/Customs and International Trade Practice, Ernst & Young, LLP "Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational." -Enrique MacGregor, Principal-in-Charge, Transfer Pricing Services Grant Thornton LLP "Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate." -Alan Getz, Vice President and General Manager, Tax Mitsui & Co., Inc. (U.S.A.) "Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner." -Per H. Hasenwinkle, National Practice Leader, Transfer Pricing BDO Seidman, LLP

Author : Mark Atkinson,David Tyrrall
Publisher : Ft Press
Page : 284 pages
File Size : 48,9 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 : Robert T. Cole
Publisher : Aspen Publishers
Page : 1302 pages
File Size : 40,6 Mb
Release : 1999
Category : International business enterprises
ISBN : PSU:000043671397

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Practical Guide to U.S. Transfer Pricing by Robert T. Cole Pdf

Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.

Author : OECD
Publisher : OECD Publishing
Page : 398 pages
File Size : 48,7 Mb
Release : 2011-12-09
Category : Electronic
ISBN : 9788691513702

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010 (Serbian version) by OECD Pdf

Author : Dr A. Michael Heimert,T.J. Michaelson
Publisher : Kluwer Law International B.V.
Page : 1290 pages
File Size : 45,6 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 : OECD
Publisher : OECD Publishing
Page : 372 pages
File Size : 55,5 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 : Dennis Manolito Weber,S. van Weeghel
Publisher : Kluwer Law International B.V.
Page : 248 pages
File Size : 50,5 Mb
Release : 2011-01-01
Category : Law
ISBN : 9789041138125

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The 2010 OECD Updates by Dennis Manolito Weber,S. van Weeghel Pdf

Virtually all international taxation provisions ultimately stem from two fundamental sources, both originating at the OECD: The Model Tax Convention (on which more than 3,000 bilateral tax treaties are based), and the Transfer Pricing Guidelines. During 2010, major revisions were made to both. This unique book provides an expert analysis of current, important topics in international taxation and transfer pricing. As such, it is a welcome and valuable resource for tax lawyers and consultants, corporate tax advisers, government officials and others involved in the international tax law market, as well as for academics and researchers in the field.