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Author : Gareth Green
Publisher : Unknown
Page : 446 pages
File Size : 52,6 Mb
Release : 2008-01-01
Category : International business enterprises
ISBN : 0906524148
Author : United Nations
Publisher : Unknown
Page : 672 pages
File Size : 55,5 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 : Robert T. Cole
Publisher : Aspen Publishers
Page : 1302 pages
File Size : 43,7 Mb
Release : 1999
Category : International business enterprises
ISBN : PSU:000043671397
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 : Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck
Publisher : Kluwer Law International B.V.
Page : 500 pages
File Size : 41,6 Mb
Release : 2019-01-03
Category : Law
ISBN : 9789041190215
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 : Robert Feinschreiber
Publisher : John Wiley & Sons
Page : 338 pages
File Size : 50,9 Mb
Release : 2004-03-01
Category : Business & Economics
ISBN : 9780471651239
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 : Oliver Treidler
Publisher : BoD – Books on Demand
Page : 76 pages
File Size : 47,6 Mb
Release : 2023-04-19
Category : Business & Economics
ISBN : 9783757835637
Transfer Pricing is an issue that has material implications for tax risks faced by MNEs. Yet, pragmatic guidance on identifying and managing transfer pricing risk is lacking. Consequently, CFOs and other stakeholders tend to underestimate risks while overestimating the costs for mitigating such risks. The first objective of the Survival Guide is to shed light on typical transfer pricing risks and provide an intuitive "risk matrix" that is designed to help CFOs as well as tax advisors to develop a quantitative understanding of the relevant risks. The second objective is to outline targeted mitigation strategies. The mitigation strategies outlined in the Survival Guide are based on pragmatic considerations rather than complex analysis. The aim is to provide you with concise explanations and help you to differentiate between tasks that are considered a "must" for mitigation purposes and those that can be regarded as merely "nice to have" The immediate utilization of the Survival Guide is as a frame of reference for making informed decisions about the scope and target of your transfer pricing projects. The Survival Guide presents a framework for thinking about transfer pricing risk that will also benefit tax professionals as well as academics with an interest in understanding the nature of transfer pricing risks.
Author : Jerome Monsenego
Publisher : Kluwer Law International B.V.
Page : 281 pages
File Size : 41,7 Mb
Release : 2022-11-22
Category : Law
ISBN : 9789403514932
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 : United Nations
Publisher : Unknown
Page : 0 pages
File Size : 50,9 Mb
Release : 2023-09-13
Category : Electronic
ISBN : 921259185X
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 : Dr A. Michael Heimert,T.J. Michaelson
Publisher : Kluwer Law International B.V.
Page : 1290 pages
File Size : 52,8 Mb
Release : 2018-10-26
Category : Law
ISBN : 9789403501710
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 : Michael Lang,Giammarco Cottani,Raffaele Petruzzi,Alfred Storck
Publisher : Unknown
Page : 0 pages
File Size : 51,9 Mb
Release : 2019
Category : International business enterprises
ISBN : 9041189947
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 : Oliver Treidler
Publisher : Unknown
Page : 138 pages
File Size : 51,8 Mb
Release : 2020
Category : Accounting
ISBN : 3030250865
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 : Ceteris
Publisher : Unknown
Page : 0 pages
File Size : 47,5 Mb
Release : 2012
Category : International business enterprises
ISBN : 9041136592
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 : Ceteris, Inc
Publisher : Unknown
Page : 0 pages
File Size : 41,8 Mb
Release : 2010
Category : International business enterprises
ISBN : 9041131213
This publication will be shortly 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
Author : Duff & Phelps
Publisher : Kluwer Law International
Page : 0 pages
File Size : 52,6 Mb
Release : 2017
Category : International business enterprises
ISBN : 904119049X
"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 : Robert Feinschreiber,Margaret Kent
Publisher : Wiley
Page : 429 pages
File Size : 49,8 Mb
Release : 2012-09-11
Category : Business & Economics
ISBN : 1118347617
Learn OECD guidance on business taxation in multiple countries A business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying more in taxes that the share of profit it generates. The Organisation for Economic Co-operation and Development (OECD) seeks to reduce the risk of business taxation in multiple countries. Transfer Pricing Handbook explores how countries can apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. It is the ultimate comprehensive guide for companies doing business globally. Helps companies properly price their goods and services for global markets Provides defenses for transfer pricing audits Provides standards for creating comparables that multijurisdictional tax administrations will accept Guides documentation requirements and timing issues If you're doing business in more than one country, Transfer Pricing Handbook is a must-have, essential guide for simplifying OECD regulations for your global company.
