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Addressing The Transfer Pricing Problem In An Origin Basis X Tax
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Book Synopsis Addressing the Transfer-pricing Problem in an Origin-basis X Tax by : David F. Bradford
Download or read book Addressing the Transfer-pricing Problem in an Origin-basis X Tax written by David F. Bradford and published by . This book was released on 2003 with total page 35 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a previous paper I described how the tax design called the X Tax would facilitate an international tax system free of many of the complexities and avoidance opportunities plaguing the existing international tax regime and also have neutrality properties generally deemed desirable. A choice must, however, be made between two basic treatments of transborder business transactions --the origin and destination principles. The destination-principle approach sidesteps the need to identify arm's length terms of transborder transactions between related business entities -- the transfer-pricing problem. This serious problem remains in the origin-principle approach, which, however, presents fewer challenges of monitoring the flow of goods and services across borders, obviates what I call the tourism problem' whereby people can reduce their taxes by consuming in a low-tax jurisdiction and, arguably most important, avoids transition effects associated with introduction of the tax and subsequent tax rate changes that occur in the destination approach. In this paper I explore possible special rules for transborder transactions between related parties in an origin-based system to eliminate the transfer-pricing problem
Book Synopsis Addressing the Transfer-Pricing Problem in an Origin-Basis X Tax by :
Download or read book Addressing the Transfer-Pricing Problem in an Origin-Basis X Tax written by and published by . This book was released on 2003 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Addressing the Transfer-pricing Poblem in an Origin-basis X Tax by : David F. Bradford
Download or read book Addressing the Transfer-pricing Poblem in an Origin-basis X Tax written by David F. Bradford and published by . This book was released on 2003 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Addressing the Trasfer Pricing Problem in an Origin Basis X Tax by : David F. Bradford
Download or read book Addressing the Trasfer Pricing Problem in an Origin Basis X Tax written by David F. Bradford and published by . This book was released on 2003 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transfer Pricing and Corporate Taxation by : Elizabeth King
Download or read book Transfer Pricing and Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2008-10-11 with total page 199 pages. Available in PDF, EPUB and Kindle. Book excerpt: National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.
Book Synopsis The X Tax in the World Economy by : David F. Bradford
Download or read book The X Tax in the World Economy written by David F. Bradford and published by A E I Press. This book was released on 2004 with total page 68 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study explores how the tax design called the X tax could alleviate the complexities and avoidance opportunities plaguing the existing U.S. system for taxing international business income.
Book Synopsis Introduction to Transfer Pricing by : Jerome Monsenego
Download or read book Introduction to Transfer Pricing written by Jerome Monsenego and published by Kluwer Law International B.V.. This book was released on 2022-11-22 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Transfer Pricing and Valuation in Corporate Taxation by : Elizabeth King
Download or read book Transfer Pricing and Valuation in Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2007-05-08 with total page 294 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer Pricing and Valuation in Corporate Taxation analyzes the disparities between both federal statutes and regulations, and r- ulations and administrative practice, in a highly controversial area of corporate tax policy: intra-company transfer pricing for tax p- poses. It addresses issues that often mean millions of dollars to in- vidual corporations, and a significant fraction of the federal gove- ment’s revenue base. These disparities between law, regulations, and administrative practice are concerning on a number of grounds. First, they - pose considerable economic costs by inducing corporations to engage in a variety of “rent-seeking” activities designed to reduce their - pected tax liabilities, and by requiring the IRS to devote still more to enforcement efforts that are very often futile. Second, they are in- ; herently undemocratic. Administrative practice is currently ad hoc by relying on dispute resolution procedures that can and do yield very different settlements on disputed tax issues from one case to another, the IRS often ends up treating similarly situated cor- rations very differently. Moreover, to the extent that the disp- ity between statute and implementation reflects the IRS’s failure to carry out Congress’ will, the laws passed by duly elected officials are effectively being superseded by administrative procedure, developed incrementally by individuals who are not answerable to an electorate.
Book Synopsis Practical Guide to U.S. Transfer Pricing by : Robert T. Cole
Download or read book Practical Guide to U.S. Transfer Pricing written by Robert T. Cole and published by Aspen Publishers. This book was released on 1999 with total page 1302 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Transfer Pricing and Multinational Enterprises Three Taxation Issues by : OECD
Download or read book Transfer Pricing and Multinational Enterprises Three Taxation Issues written by OECD and published by OECD Publishing. This book was released on 1984-10-01 with total page 90 pages. Available in PDF, EPUB and Kindle. Book excerpt: Digitised document - Electronic release on 24/11/2011
Book Synopsis Fundamental Capital Income Tax Reforms by : Michael Stimmelmayr
Download or read book Fundamental Capital Income Tax Reforms written by Michael Stimmelmayr and published by Mohr Siebeck. This book was released on 2007 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt: Originally presented as the author's thesis (doctoral)--Ludwig-Maximilians-Universitèat Mèunchen, 2007.
Download or read book Working Paper Series written by and published by . This book was released on 2003 with total page 548 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Reform in Open Economies by : Iris Claus
Download or read book Tax Reform in Open Economies written by Iris Claus and published by Edward Elgar Publishing. This book was released on 2010-01-01 with total page 341 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book brings together research from some of the world s leading tax economists to discuss appropriate directions for tax reform in small open economies. The eminent contributors (including Altshuler, Creedy, Freebairn, Gravelle, Heady, Kalb, Sørensen and Zodrow) investigate the beneficial directions for medium-term tax reform in the light of global developments and lessons from the latest taxation research. In addressing this issue, they review recent advances in both the theoretical and empirical tax literature and reform evidence from individual countries. Topics covered include the impact of taxes on economic performance; international and corporate taxation; personal tax and welfare systems; environmental taxation; and country-specific tax reform experiences. Bringing together leading international experts to explore specific policy reforms, this book will prove essential reading for academics and researchers of public economics, fiscal policy and tax reform. It will also be warmly welcomed both by undergraduate and graduate students of public economics or the economics of taxation, as well as policymakers and government officials working in the area of tax policy.
Book Synopsis Taxing Capital Income by : Henry J. Aaron
Download or read book Taxing Capital Income written by Henry J. Aaron and published by The Urban Insitute. This book was released on 2007 with total page 372 pages. Available in PDF, EPUB and Kindle. Book excerpt: The question of whether to tax income from wealth has sparked debate since our country's inception. Does taxing capital income ensure the progressivity of our system or merely discourage saving? Would switching our tax code to one that taxes only consumption be more efficient or only burden middle- and low-income people? And if we were to radically reform the way America taxes its citizens, how could we ensure that vital revenue would not be lost? Some analysts would even argue that, under our present byzantine tax system, we don't really tax capital income at all. In this volume, eminent economists analyze the problems associated with taxing capital income and propose policy solutions, which are then challenged by their peers in informed commentary. It may not settle the debate, but policymakers, scholars, and the public will find a wealth of information and ideas to consider.
Book Synopsis The Economics of Tax Policy by : Alan J. Auerbach
Download or read book The Economics of Tax Policy written by Alan J. Auerbach and published by Oxford University Press. This book was released on 2017 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Debates about the optimal structure for tax policies and tax rates hardly cease among public, policy, or academic audiences. These have only grown more heated in the United States as the gap between incomes of the wealthiest 1 percent and the rest of the population continue to diverge. Tax research perhaps has not fully kept pace with the relentless demand of various interests to adjust tax policy. Nonetheless, specialists in the economics of tax policy in recent years have profited from advances in economic theory, econometric measurements, and data quality and access that are beginning to allow a greater consensus on what are the real effects of tax policy and how government levies affect individuals and businesses. The volume edited by Professors Auerbach and Smetters represents an attempt to reduce the lag between the conduct of research on tax issues and its transmission to a broader public. The contributions would explore highly topical issues such as the effects of income tax changes on economic growth, the potential effects of capping certain tax expenditures, the economics of adjusted business tax policy, and environmental tax options. Other essays would investigate perennially important themes such as the conduct of tax administration, the growing role of the tax system on education policy, tax policy toward low-income families, capital gains and estate taxation, and tax policy for retirement savings. A final paper would examine three different options for fundamental tax reform"--
Book Synopsis OECD Tax Policy Studies Fundamental Reform of Corporate Income Tax by : OECD
Download or read book OECD Tax Policy Studies Fundamental Reform of Corporate Income Tax written by OECD and published by OECD Publishing. This book was released on 2007-11-13 with total page 174 pages. Available in PDF, EPUB and Kindle. Book excerpt: Presents the recent trends in the taxation of corporate income in OECD countries, discusses the main drivers of corporate income tax reform and evaluates the gains of fundamental corporate tax reform.
Book Synopsis The X Tax in the World Economy by : David F. Bradford
Download or read book The X Tax in the World Economy written by David F. Bradford and published by . This book was released on 2004 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt: "This paper considers the treatment of multinational business in the system known as an X Tax. The focus is on the choice between origin and destination treatments of transborder transactions. The destination-principle approach sidesteps the transferpricing problem. It remains in the origin-principle approach, which, however, presents fewer challenges of monitoring imports, obviates the tourism problem' whereby people can reduce their taxes by consuming in a low-tax jurisdiction and avoids transition effects associated with introduction of the tax and subsequent tax rate changes. The paper suggests special rules for transborder transactions between related parties to deal with the transfer-pricing problem"--NBER website
