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Advance Pricing Agreementsa Global Analysis Is There A Safe Harbour For Multinational Enterprises Operating In A Global Economy
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Book Synopsis Advance Pricing Agreements:A Global Analysis: Is There a Safe Harbour for Multinational Enterprises Operating in a Global Economy? by : Jose Carrero
Download or read book Advance Pricing Agreements:A Global Analysis: Is There a Safe Harbour for Multinational Enterprises Operating in a Global Economy? written by Jose Carrero and published by Springer. This book was released on 1998-10-16 with total page 184 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Advance pricing agreements : a global analysis ; is there a safe harbour for multinational enterprises operating in a global economy? by :
Download or read book Advance pricing agreements : a global analysis ; is there a safe harbour for multinational enterprises operating in a global economy? written by and published by . This book was released on 1998 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 by : OECD
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 written by OECD and published by OECD Publishing. This book was released on 2022-01-20 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 by : OECD
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 written by OECD and published by OECD Publishing. This book was released on 2017-07-10 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis The Transfer Pricing of Intangibles by : Michelle Markham
Download or read book The Transfer Pricing of Intangibles written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2005-01-01 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.
Book Synopsis Transfer Pricing Developments Around the World 2019 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2019 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2019-08-09 with total page 290 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Fundamentals of Transfer Pricing by : Michael Lang
Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2019-01-03 with total page 500 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Comparative Law Yearbook of International Business Volume 43 by : Christian Campbell
Download or read book Comparative Law Yearbook of International Business Volume 43 written by Christian Campbell and published by Kluwer Law International B.V.. This book was released on 2021-11-11 with total page 195 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Comparative Law Yearbook of International Business, published under the auspices of the Center for International Legal Studies, in this 43rd volume spans an arc of timely and challenging concerns for business law practitioners and academics alike. It discusses: how arbitrability of intellectual property rights disputes might improve worldwide IPR enforcement; how the “disregard of legal entity” may be used to establish implied consent by a person or entity that is not a signatory to an arbitration agreement; how an effective cross-border insolvency framework under the Indian insolvency and bankruptcy code can borrow from the UNCITRAL Model Law’s and other jurisdictions’ approaches to the tension between “universality” and “territoriality”; how a promising new mediation act for Pakistan may help resolve a backlog of millions of cases in a jurisdiction with a patchwork of traditional and modern alternative dispute resolution mechanisms; how the European Union seeks to balance the taxation of digital services; how Brazil is addressing the taxation of offshore indirect transfers; how private equity capital structures in the unique market of professional sports create opportunities as well as risks; how Securities Market Regulation theory plays a role in the organization and development of active securities markets, particularly in emerging markets; and how non-signatories can be bound by arbitration agreements in Brazil through “disregard of legal entity” to ascertain implied consent. The authors are practitioners and academics from Brazil, England, France, India, Pakistan, Singapore, the United States and Uzbekistan. They offer a broad and diverse perspective on some of today’s pressing business law issues in a shrinking world.
Download or read book Canadian Tax Journal written by and published by . This book was released on 1999 with total page 822 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :Organisation for Economic Co-operation and Development Publisher :Organisation for Economic Co-operation and Development ISBN 13 : Total Pages :74 pages Book Rating :4.F/5 ( download)
Book Synopsis Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations by : Organisation for Economic Co-operation and Development
Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development. This book was released on 1995 with total page 74 pages. Available in PDF, EPUB and Kindle. Book excerpt: Includes 1999 update. 1998 update in back.
Book Synopsis Introduction to Transfer Pricing by : Jerome Monsenego
Download or read book Introduction to Transfer Pricing written by Jerome Monsenego and published by . This book was released on 2013-01-01 with total page 163 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.
Book Synopsis Transfer Pricing Handbook by : Robert Feinschreiber
Download or read book Transfer Pricing Handbook written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2012-08-03 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 by : United Nations
Download or read book United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 written by United Nations and published by . This book was released on 2017 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Index to Legal Periodicals & Books by :
Download or read book Index to Legal Periodicals & Books written by and published by . This book was released on 2003 with total page 2072 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Radhakishan Rawal’s Analysis of the Finance Acts of 2019 and More by : Radhakishan Rawal
Download or read book Radhakishan Rawal’s Analysis of the Finance Acts of 2019 and More written by Radhakishan Rawal and published by Bloomsbury Publishing. This book was released on 2019-10-30 with total page 235 pages. Available in PDF, EPUB and Kindle. Book excerpt: About the book This book contains detailed analysis of some of the key provisions of the Finance Acts passed during the year 2019 i.e. Finance Act, 2019 and Finance (No.2) Act, 2019. The book aims at identifying various direct and indirect tax issues arising from the newly inserted provisions in the Income Tax Act, 1961 as well as the Goods and Services Tax Act, 2017. The book also contains a detailed chapter on Secondary Adjustment. The key direct tax issues analysed in this book are related to sections 9(1)(viii), section 79, section 92CE, section 115UB, section 194N, section 194DA and provisions related to International Financial Services Center (IFSC) of the Income Tax Act, 1961. Additionally, the book also contains other articles written by the author on issues such as GAAR and Financial Instruments, proposed Rule 10 on attribution of profits and MLI. The key indirect tax issues analysed in this book are related to section 2(102), sections 7, section 22, section 171 and section 172 of the Central Goods and Services Tax Act, 2017. Key features Analysis of direct tax law Section 9(1)(viii), section 79, section 115UB, section 194N Taxation of life insurance policy and section 194DA Secondary adjustment IFSC related provisions GAAR and Financial Instruments Attribution of profits (proposed Rule 10) MLI operations Analysis of GST law Amendment to definition of “supply” Amendment to definition of “service” Anti-profiteering and concept of “amount profiteered” National Appellate Authority for Advance Ruling
Book Synopsis World Development Report 2020 by : World Bank
Download or read book World Development Report 2020 written by World Bank and published by World Bank Publications. This book was released on 2019-11-19 with total page 511 pages. Available in PDF, EPUB and Kindle. Book excerpt: Global value chains (GVCs) powered the surge of international trade after 1990 and now account for almost half of all trade. This shift enabled an unprecedented economic convergence: poor countries grew rapidly and began to catch up with richer countries. Since the 2008 global financial crisis, however, the growth of trade has been sluggish and the expansion of GVCs has stalled. Meanwhile, serious threats have emerged to the model of trade-led growth. New technologies could draw production closer to the consumer and reduce the demand for labor. And trade conflicts among large countries could lead to a retrenchment or a segmentation of GVCs. World Development Report 2020: Trading for Development in the Age of Global Value Chains examines whether there is still a path to development through GVCs and trade. It concludes that technological change is, at this stage, more a boon than a curse. GVCs can continue to boost growth, create better jobs, and reduce poverty provided that developing countries implement deeper reforms to promote GVC participation; industrial countries pursue open, predictable policies; and all countries revive multilateral cooperation.
Book Synopsis Multinational Enterprises and the Global Economy by : John H. Dunning
Download or read book Multinational Enterprises and the Global Economy written by John H. Dunning and published by Edward Elgar Publishing. This book was released on 2008-01-01 with total page 947 pages. Available in PDF, EPUB and Kindle. Book excerpt: For many years to come this volume. . .is surely going to be the ultimate reference work on international business. . . thanks to Dunning and Lundan, have at their disposal, a wealth of relevant data, as well as theoretical and empirical analyses, which will enable them to assess the capabilities, contributions and challenges posed by the multinational enterprises to the global economy. Seev Hirsch, International Business Review Multinational Enterprises and the Global Economy has become a classic in international business. . . Yet , the book s second edition is even better than the first, in part because of Professor Dunning s wise decision to choose Dr Lundan as his co-author and to draw upon her deep knowledge of various strands of research on business government relations and the societal effects of firm behaviour. . . In addition to being a remarkably useful reference book, Multinational Enterprises and the Global Economy is the first book any IB doctoral student should read to understand the significance and richness of IB scholarship as it has developed over the past 50 years. Alain Verbeke, Journal of International Business Studies The second edition of Multinational Enterprises and the Global Economy provides unparalleled coverage not only of the literature relevant to IB research but also of the evolution of IB in the world economy. Dunning and Lundan offer powerful insights into the societal effects of MNEs and the role of business government relations in the IB context. Journal of International Business Studies This wonderful book offers the definitive synthesis of the modern literature on the economic aspects of international business. It is encyclopedic yet full of incisive insights. It is a creative masterpiece which unbundles the DNA of the multinational enterprise and shows how it is the cornerstone of the field of international business. Alan M. Rugman, University of Reading, UK The rise of the multinational enterprise, and the consequent globalisation of the world economy, was arguably the single most important phenomenon of the second half of the twentieth century. This magisterial book, written by two leading authorities, examines this phenomenon in depth. It explains how foreign investment by multinationals diffused advanced technologies and novel management methods, driving productivity growth in Europe, Asia and North America; however, economic inequalities were reinforced as rich countries attracted more foreign investment than poor ones. This new edition of a classic work is not only an authoritative guide to contemporary multinational business, but a major historical resource for the future. Mark Casson, University of Reading, UK This thoroughly updated and revised edition of a widely acclaimed, classic text will be required reading for academics, policymakers and advanced students of international business worldwide. Employing a distinctive and unified framework, this book draws together research across a range of academic fields to offer a synthesis of the determinants of MNE activity, and its effects on the economic and social well-being of developed and developing countries. Unique to the new edition is its focus on the institutional underpinnings of the resources and capabilities of MNEs, and the role of MNE activity in transmitting and facilitating institutional change. Since the initial publication of this book more than a decade ago, the economic, managerial and social implications of globalisation and technological advancement have become even more varied and prominent. Accompanying these developments, there has been a rise in scholarly interest in interdisciplinary research addressing the important challenges of an ever-changing physical and human environment. Drawing on articles and books from international business and economics, as well as economic geography, political economy and strategic management, a systematic overview of the developments in scholarly thinking is prese
