Transfer Pricing And The Arm S Length Principle In International Tax Law

Transfer Pricing And The Arm S Length Principle In International Tax Law Book in PDF, ePub and Kindle version is available to download in english. Read online anytime anywhere directly from your device. Click on the download button below to get a free pdf file of Transfer Pricing And The Arm S Length Principle In International Tax Law book. This book definitely worth reading, it is an incredibly well-written.

Transfer Pricing and the Arm's Length Principle in International Tax Law

Jens Wittendorff
Transfer Pricing and the Arm s Length Principle in International Tax Law Book PDF

Author : Jens Wittendorff
Publisher : Kluwer Law International B.V.
Page : 914 pages
File Size : 48,6 Mb
Release : 2010-01-01
Category : Law
ISBN : 9789041132703

Get Book

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.

Fundamentals of International Transfer Pricing in Law and Economics

Wolfgang Schön,Kai A. Konrad
Fundamentals of International Transfer Pricing in Law and Economics Book PDF

Author : Wolfgang Schön,Kai A. Konrad
Publisher : Springer Science & Business Media
Page : 306 pages
File Size : 41,7 Mb
Release : 2012-02-15
Category : Law
ISBN : 9783642259807

Get Book

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.

Contemporary Application of the Arm's Length Principle in Transfer Pricing

Marta Pankiv
Contemporary Application of the Arm s Length Principle in Transfer Pricing Book PDF

Author : Marta Pankiv
Publisher : Unknown
Page : 242 pages
File Size : 53,6 Mb
Release : 2017
Category : International business enterprises
ISBN : 9087224133

Get Book

Contemporary Application of the Arm's Length Principle in Transfer Pricing by Marta Pankiv Pdf

This book outlines how the application of the arm?s length principle should be reconsidered in light of the initiative of the OECD and G20 to counter tax base erosion and profit shifting (BEPS). The arm?s length principle embedded in article 9 of the OECD Model is not an anti-avoidance rule and has been misidentified as the primary tool for tackling abusive practices. Transfer pricing analysis, commonly understood as examining economic substance, in reality examines whether related parties have the functional and financial capacity to perform the contracts they have entered into.

Transfer Pricing and Value Creation

Raffaele Petruzzi,Romero J.S. Tavares Esq.
Transfer Pricing and Value Creation Book PDF

Author : Raffaele Petruzzi,Romero J.S. Tavares Esq.
Publisher : Linde Verlag GmbH
Page : 472 pages
File Size : 49,6 Mb
Release : 2019-09-02
Category : Law
ISBN : 9783709410387

Get Book

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.

Fundamentals of Transfer Pricing

Michael Lang,Giammarco Cotani,Raffaele Petruzzi
Fundamentals of Transfer Pricing Book PDF

Author : Michael Lang,Giammarco Cotani,Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
Page : 484 pages
File Size : 52,7 Mb
Release : 2021-06-18
Category : Law
ISBN : 9789403517247

Get Book

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.

International Tax Law

Passemard Hugo
International Tax Law Book PDF

Author : Passemard Hugo
Publisher : Blurb
Page : 210 pages
File Size : 45,9 Mb
Release : 2020-05-16
Category : Electronic
ISBN : 1714893898

Get Book

International Tax Law by Passemard Hugo Pdf

Transfer pricing remains one of the biggest areas of heightened controversy in worldwide taxation for multinational firms and tax administrations. Due to its long-reaching effects, tax professionals and tax jurisdictions are required to apprehend the basics of the subject. H. Passemard designed this monograph to act as a guide for understanding Transfer Pricing principles and their practical application. It provides a levelled approach by first and foremost detailing the Transfer Pricing fundamentals and then proceeding to specific topics that are extremely relevant in our current tax environment. The book 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.

Advanced Introduction to International Tax Law

Reuven S. Avi-Yonah
Advanced Introduction to International Tax Law Book PDF

Author : Reuven S. Avi-Yonah
Publisher : Edward Elgar Publishing
Page : 231 pages
File Size : 40,7 Mb
Release : 2019
Category : Double taxation
ISBN : 9781788978491

Get Book

Advanced Introduction to International Tax Law by Reuven S. Avi-Yonah Pdf

This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.

Fundamentals of Transfer Pricing

Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck
Fundamentals of Transfer Pricing Book PDF

Author : Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck
Publisher : Kluwer Law International B.V.
Page : 500 pages
File Size : 40,9 Mb
Release : 2019-01-03
Category : Law
ISBN : 9789041190215

Get Book

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.

The 2010 OECD Updates

Dennis Manolito Weber,S. van Weeghel
The 2010 OECD Updates Book PDF

Author : Dennis Manolito Weber,S. van Weeghel
Publisher : Kluwer Law International B.V.
Page : 248 pages
File Size : 41,5 Mb
Release : 2011-01-01
Category : Law
ISBN : 9789041138125

Get Book

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.

Guide to International Transfer Pricing

Dr A. Michael Heimert,T.J. Michaelson
Guide to International Transfer Pricing Book PDF

Author : Dr A. Michael Heimert,T.J. Michaelson
Publisher : Kluwer Law International B.V.
Page : 1290 pages
File Size : 54,8 Mb
Release : 2018-10-26
Category : Law
ISBN : 9789403501710

Get Book

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.

Practical Guide to U.S. Transfer Pricing

Robert T. Cole
Practical Guide to U S Transfer Pricing Book PDF

Author : Robert T. Cole
Publisher : Aspen Publishers
Page : 1302 pages
File Size : 47,5 Mb
Release : 1999
Category : International business enterprises
ISBN : PSU:000043671397

Get Book

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.

Tax Transfer Pricing

Andrea Musselli
Tax Transfer Pricing Book PDF

Author : Andrea Musselli
Publisher : Gruppo 24 Ore
Page : 446 pages
File Size : 46,5 Mb
Release : 2022-09-15T00:00:00+02:00
Category : Business & Economics
ISBN : 9791254831540

Get Book

Tax Transfer Pricing by Andrea Musselli Pdf

The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.

Transfer Pricing and Multinational Enterprises

OECD
Transfer Pricing and Multinational Enterprises Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 107 pages
File Size : 40,6 Mb
Release : 1979-06-01
Category : Electronic
ISBN : 9789264167773

Get Book

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.

International Tax Policy and Double Tax Treaties

Kevin Holmes
International Tax Policy and Double Tax Treaties Book PDF

Author : Kevin Holmes
Publisher : IBFD
Page : 433 pages
File Size : 41,7 Mb
Release : 2007
Category : Double taxation
ISBN : 9789087220235

Get Book

International Tax Policy and Double Tax Treaties by Kevin Holmes Pdf

Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.

Arm’s Length Transaction Structures

Andreas Bullen
Arm s Length Transaction Structures Book PDF

Author : Andreas Bullen
Publisher : IBFD
Page : 925 pages
File Size : 44,6 Mb
Release : 2011
Category : Corporations
ISBN : 9789087221171

Get Book

Arm’s Length Transaction Structures by Andreas Bullen Pdf

This book examines the authority to restructure and to disregard controlled transactions based on the arm's length principle. The book, thus, examines the outer limits of the adjustment authority granted by the arm's length principle as opposed to its core area of application (price adjustments).