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Author : Anonim
Publisher : Unknown
Page : 9 pages
File Size : 52,8 Mb
Release : 2012
Category : Electronic
ISBN : 3864980593
Author : Anuschka Bakker,Marc M. Levey,International Bureau of Fiscal Documentation
Publisher : IBFD
Page : 593 pages
File Size : 45,9 Mb
Release : 2012
Category : Business & Economics
ISBN : 9789087221522
This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
Author : Michael Lang,Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
Page : 312 pages
File Size : 46,7 Mb
Release : 2020-09-28
Category : Law
ISBN : 9789403523934
Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the 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), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Author : Wolfgang Schön,Kai A. Konrad
Publisher : Springer Science & Business Media
Page : 308 pages
File Size : 44,5 Mb
Release : 2012-02-15
Category : Law
ISBN : 9783642259807
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.
Author : Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra
Publisher : World Bank Publications
Page : 388 pages
File Size : 46,5 Mb
Release : 2017-01-05
Category : Business & Economics
ISBN : 9781464809705
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 : Michael Lang,Raffaele Petruzzi,Alfred Storck
Publisher : Kluwer Law International B.V.
Page : 290 pages
File Size : 53,8 Mb
Release : 2019-08-09
Category : Law
ISBN : 9789403512839
Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the 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), this book offers eight topic-based papers prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on Transfer Pricing and Intra-Group Services; Recent Developments on Transfer Pricing and Intra-Group Financing; Recent Developments on the Nexus Rules to Tax Business Profits at Source; and Recent Developments on Attribution of Profits to Digital Permanent Establishments. The intense work of international organizations such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Author : Raffaele Petruzzi,Michael Lang
Publisher : Kluwer Law International B.V.
Page : 261 pages
File Size : 48,9 Mb
Release : 2023-03-09
Category : Law
ISBN : 9789403540337
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 : United Nations Department of Economic and Social Affairs
Publisher : United Nations
Page : 592 pages
File Size : 48,6 Mb
Release : 2015-12-15
Category : Political Science
ISBN : 9789210572361
Taxation plays a critical role in promoting sustainable development and developing countries face significant challenges in mobilizing domestic resources. This publication analyses a number of topics which are of particular interest and relevance to developing countries in raising revenues and protecting the tax base. It aims at providing practical assistance to these countries in assessing and addressing the relevant issues in an effective way. Primary audiences are officials of national tax authorities and ministries of finance in developing countries, other professionals dealing with tax matters, the general public, media and universities.
Author : United Nations Conference on Trade and Development
Publisher : Unknown
Page : 76 pages
File Size : 42,5 Mb
Release : 1999
Category : Business & Economics
ISBN : MINN:31951D017552964
This paper on transfer pricing is part of the "UNCTAD Series on issues in international investment agreements". It provides balanced analysis of issues that may arise in discussions about international investment agreements.
Author : OECD
Publisher : OECD Publishing
Page : 659 pages
File Size : 45,7 Mb
Release : 2022-01-20
Category : Electronic
ISBN : 9789264921917
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.
Author : OECD
Publisher : OECD Publishing
Page : 608 pages
File Size : 49,5 Mb
Release : 2017-07-10
Category : Electronic
ISBN : 9789264265127
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 : United Nations
Publisher : Unknown
Page : 672 pages
File Size : 43,5 Mb
Release : 2017
Category : Business & Economics
ISBN : UIUC:30112116051332
The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.
Author : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs
Publisher : Organisation for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Center
Page : 104 pages
File Size : 46,6 Mb
Release : 1984-10
Category : Double taxation
ISBN : UCAL:B4179846
Digitised document - Electronic release on 24/11/2011
Author : OECD
Publisher : OECD Publishing
Page : 110 pages
File Size : 46,9 Mb
Release : 2012-01-18
Category : Electronic
ISBN : 9789264169463
This report addresses the practical administration of transfer pricing programmes by tax administrations.
Author : Steve Edge,Dominic Robertson
Publisher : Unknown
Page : 0 pages
File Size : 48,7 Mb
Release : 2023
Category : Electronic
ISBN : 1804491780
