Transfer Pricing And Tax Avoidance

Author : David Wallen Chodikoff
Publisher : Unknown
Page : 0 pages
File Size : 50,9 Mb
Release : 2014-10-03
Category : International business enterprises
ISBN : 0414033507

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Transfer Pricing and Tax Avoidance by David Wallen Chodikoff Pdf

This is a cross-jurisdictional reference book covering over 30 jurisdictions. It is split into two sections. Part one focuses upon transfer pricing. It gives the legislative framework, national policies and administrative approaches to transfer pricing; case law - current and past; penalties; special or notable cases related to penalties and finally, national and relevant international dispute resolution mechanisms. Part two is focused upon providing an overview of tax avoidance (and even more specifically, abusive tax avoidance). In order to help distinguish between legitimate tax avoidance plans or schemes, the first section identifies plans that remain valid as legitimate ways to minimize tax. Defining abusive tax avoidance is the second section - some nations are still struggling to define a satisfactory definition or parameters that constitute abusive tax avoidance. Other states have fully outlined the scope of abusive tax avoidance. The third section deals with the legislative framework. Followed by a section on case law and following that a section on penalties and finally, a section on current trends. This last section covers current national policy and legal trends and how international policies have in any way effected/shaped a jurisdiction's national policies.

Author : Sebastian Beer,Ruud A. de Mooij,Ms.Li Liu
Publisher : International Monetary Fund
Page : 45 pages
File Size : 53,6 Mb
Release : 2018-07-23
Category : Business & Economics
ISBN : 9781484363997

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International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots by Sebastian Beer,Ruud A. de Mooij,Ms.Li Liu Pdf

This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.

Author : Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra
Publisher : World Bank Publications
Page : 388 pages
File Size : 54,6 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 : Jerome Monsenego
Publisher : Kluwer Law International B.V.
Page : 281 pages
File Size : 52,5 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 : Ganapati Bhat
Publisher : Unknown
Page : 32 pages
File Size : 54,9 Mb
Release : 2009
Category : Transfer pricing
ISBN : 3889854559

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Transfer Pricing, Tax Havens and Global Governance by Ganapati Bhat Pdf

Author : OECD
Publisher : OECD Publishing
Page : 107 pages
File Size : 43,9 Mb
Release : 1979-06-01
Category : Electronic
ISBN : 9789264167773

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Transfer Pricing and Multinational Enterprises by OECD Pdf

The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.

Author : Robert Turner
Publisher : Unknown
Page : 36 pages
File Size : 50,5 Mb
Release : 1996
Category : Transfer pricing
ISBN : MINN:31951D01429383S

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Study on Transfer Pricing by Robert Turner Pdf

Author : Antonio De Vito
Publisher : Springer Nature
Page : 185 pages
File Size : 42,9 Mb
Release : 2024-06-29
Category : Electronic
ISBN : 9783031517655

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Tax Avoidance Research by Antonio De Vito Pdf

Author : David Wallen Chodikoff
Publisher : Unknown
Page : 670 pages
File Size : 41,5 Mb
Release : 2017
Category : International business enterprises
ISBN : 041406285X

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Transfer Pricing by David Wallen Chodikoff Pdf

This is a cross-jurisdictional reference book covering over 38 jurisdictions. It is split into two sections. Part one focuses upon transfer pricing. It gives the legislative framework, national policies and administrative approaches to transfer pricing; case law - current and past; penalties; special or notable cases related to penalties and finally, national and relevant international dispute resolution mechanisms. Part two is focused upon providing an overview of tax avoidance (and even more specifically, abusive tax avoidance). In order to help distinguish between legitimate tax avoidance plans or schemes, the first section identifies plans that remain valid as legitimate ways to minimize tax. Defining abusive tax avoidance is the second section - some nations are still struggling to define a satisfactory definition or parameters that constitute abusive tax avoidance. Other states have fully outlined the scope of abusive tax avoidance. The third section deals with the legislative framework. Followed by a section on case law and following that a section on penalties and finally, a section on current trends. This last section covers current national policy and legal trends and how international policies have in any way effected/shaped a jurisdiction's national policies.

Author : Wagdy M. Abdallah
Publisher : Bloomsbury Publishing USA
Page : 272 pages
File Size : 46,6 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 : OECD
Publisher : OECD Publishing
Page : 92 pages
File Size : 46,5 Mb
Release : 2011-08-03
Category : Electronic
ISBN : 9789264119222

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Corporate Loss Utilisation through Aggressive Tax Planning by OECD Pdf

After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.

Author : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs
Publisher : Organization for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Centre
Page : 124 pages
File Size : 45,6 Mb
Release : 1987
Category : Double taxation
ISBN : UCSD:31822003577673

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International Tax Avoidance and Evasion by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs Pdf

Compilation of four related studies.

Author : Eric J. Bartelsman,Roel M. W. J. Beetsma
Publisher : Unknown
Page : 36 pages
File Size : 42,6 Mb
Release : 2000
Category : Corporations
ISBN : UVA:X006111373

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Why Pay More? by Eric J. Bartelsman,Roel M. W. J. Beetsma Pdf

Author : Fouad Sabry
Publisher : One Billion Knowledgeable
Page : 304 pages
File Size : 50,7 Mb
Release : 2024-03-28
Category : Business & Economics
ISBN : PKEY:6610000545032

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Transfer Pricing by Fouad Sabry Pdf

What is Transfer Pricing Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm's length. The OECD and World Bank recommend intragroup pricing rules based on the arm's-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative practice. Countries with transfer pricing legislation generally follow the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in most respects, although their rules can differ on some important details. How you will benefit (I) Insights, and validations about the following topics: Chapter 1: Transfer pricing Chapter 2: Tax deduction Chapter 3: Capital gain Chapter 4: Tax treaty Chapter 5: Corporate tax Chapter 6: Indirect tax Chapter 7: Partnership taxation in the United States Chapter 8: Arm's length principle Chapter 9: Gross income Chapter 10: International taxation Chapter 11: Tax consolidation Chapter 12: Patent valuation Chapter 13: Optimal tax Chapter 14: Advance pricing agreement Chapter 15: Corporate tax in the United States Chapter 16: Foreign tax credit Chapter 17: Transactional net margin method Chapter 18: Transfer mispricing Chapter 19: Canada v GlaxoSmithKline Inc Chapter 20: Base erosion and profit shifting Chapter 21: Base erosion and profit shifting (OECD project) (II) Answering the public top questions about transfer pricing. (III) Real world examples for the usage of transfer pricing in many fields. Who this book is for Professionals, undergraduate and graduate students, enthusiasts, hobbyists, and those who want to go beyond basic knowledge or information for any kind of Transfer Pricing.

Author : Lorraine Eden
Publisher : University of Toronto Press
Page : 788 pages
File Size : 45,6 Mb
Release : 1998-01-01
Category : Business & Economics
ISBN : 0802007767

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Taxing Multinationals by Lorraine Eden Pdf

Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.