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Advance Pricing Arrangement Series Americas
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Book Synopsis Advance Pricing Arrangement Series : Americas by : Matthew Frank
Download or read book Advance Pricing Arrangement Series : Americas written by Matthew Frank and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance pricing agreements keep getting more important. APAs save resources for both the participating companies and tax authorities. The authors show how the programs are working and growing in the Americas.
Book Synopsis Advance Pricing Agreements by : Michelle Markham
Download or read book Advance Pricing Agreements written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2012-06-28 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing (the pricing of cross-border intra-firm transactions between related parties) is now the top international tax issue faced by multinational enterprises. In an international taxation environment characterized by rigorous enforcement of transfer pricing documentation, disclosure, and audit processes, a need has arisen for multinationals to be cognizant of the impact of their ‘tax risk appetite’ on their relationship with taxation authorities and to be aware of how best to manage their transfer pricing arrangements. The most promising development has been the growing commitment to Advance Pricing Agreements (APAs) – arrangements made prospectively between a multinational taxpayer and one or more revenue authorities, agreeing on an appropriate set of criteria for the determination of the transfer pricing of the covered transactions over a period of time. This is the first book to offer expert insights on APAs from a practical perspective. By focusing on the United States and Australia, the two countries that were at the forefront of adopting APAs and whose wealth of experience over two decades confirms their APA programs as the global paradigms, the author is able to highlight the advantages and disadvantages of pursuing an APA and to shed light on the powerful efficacy of this strategy for avoiding transfer pricing disputes. In addition, the author enlists the views of revenue authorities, transfer pricing practitioners, and corporate counsel who deal with the realities of transfer pricing assessment and compliance on an ongoing basis, offering acute insight into how APAs really work in a practical way. This book contributes to the body of knowledge on APAs in the context of transfer pricing by providing in-depth scrutiny of the most important issues surrounding this critical area, and by examining innovations in APAs in the United States and in Australia. Its unmatched coverage will be welcomed by tax experts at law firms and multinational companies as well as by revenue officials, policymakers, and scholars and researchers in international taxation.
Book Synopsis Negotiating an Advance Pricing Agreement by : Joseph B. Kennedy
Download or read book Negotiating an Advance Pricing Agreement written by Joseph B. Kennedy and published by . This book was released on 1996 with total page 6 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Rules and Compliance Handbook by : Marc M. Levey
Download or read book Transfer Pricing Rules and Compliance Handbook written by Marc M. Levey and published by CCH. This book was released on 2006 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book gives an overview of the basic principles of transfer pricing and U.S. transfer pricing rules, and the impact of transfer pricing on other issues such as customs valuation, Section 404 of the Sarbanes-Oxley Act of 2002, and FASB Interpretation no. 48.
Book Synopsis The Code of Federal Regulations of the United States of America by :
Download or read book The Code of Federal Regulations of the United States of America written by and published by . This book was released on 2005 with total page 1124 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Code of Federal Regulations is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government.
Book Synopsis WTO - Trade in Goods by : Rüdiger Wolfrum
Download or read book WTO - Trade in Goods written by Rüdiger Wolfrum and published by BRILL. This book was released on 2010-12-07 with total page 1266 pages. Available in PDF, EPUB and Kindle. Book excerpt: Article-by-article this volume explains the GATT 1994, its Introductory Note and Annexes, the Understandings on Arts II:1 lit. b, XVII, XXIV and XXVIII GATT, the Understandings on Balance-of-Payments Provisions and Waivers of Obligations, the Enabling Clause and the Waiver on Preferential Tariff Treatment for Least-Developed Countries. It also covers the Agreements on Customs Valuation, Preshipment Inspection and Rules of Origin.
Book Synopsis International Taxation of Permanent Establishments by : Michael Kobetsky
Download or read book International Taxation of Permanent Establishments written by Michael Kobetsky and published by Cambridge University Press. This book was released on 2011-09-15 with total page 469 pages. Available in PDF, EPUB and Kindle. Book excerpt: The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
Book Synopsis Medicare and the American Health Care System by :
Download or read book Medicare and the American Health Care System written by and published by . This book was released on 1995 with total page 180 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Tax Disputes by : Hans Mooij
Download or read book International Tax Disputes written by Hans Mooij and published by Edward Elgar Publishing. This book was released on 2024-06-05 with total page 361 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bringing together global experts from diverse legal backgrounds, this comprehensive book offers a rigorous analysis of the complexity of resolving and preventing international tax disputes, covering arbitration, mediation, and dispute management. Presenting an authoritative overview of international tax disputes, this book will be indispensable to practitioners in corporate and international tax, controversy and dispute specialists, and investment arbitration lawyers.
Book Synopsis Taxing Multinationals by : Lorraine Eden
Download or read book Taxing Multinationals written by Lorraine Eden and published by University of Toronto Press. This book was released on 1998-01-01 with total page 788 pages. Available in PDF, EPUB and Kindle. Book excerpt: Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.
Book Synopsis Arm’s Length Transaction Structures by : Andreas Bullen
Download or read book Arm’s Length Transaction Structures written by Andreas Bullen and published by IBFD. This book was released on 2011 with total page 925 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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).
Book Synopsis Ebook: Managerial Economics and Organizational Architecture by : Brickley
Download or read book Ebook: Managerial Economics and Organizational Architecture written by Brickley and published by McGraw Hill. This book was released on 2015-05-16 with total page 836 pages. Available in PDF, EPUB and Kindle. Book excerpt: Ebook: Managerial Economics and Organizational Architecture
Book Synopsis Federal Estate & Gift Taxes by : CCH Incorporated
Download or read book Federal Estate & Gift Taxes written by CCH Incorporated and published by CCH. This book was released on 2008-04 with total page 1632 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis U.S. Customs by : Michael D. Sherman
Download or read book U.S. Customs written by Michael D. Sherman and published by American Bar Association. This book was released on 2009 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt: Provides general overview and addresses three major areas of interest for all importers (compliance, enforcement, trade security). The book covers: -Fundamental elements of lawful importation, i.e., the importation process itself, classification, valuation, marking, and duty savings opportunities -Importer's recordkeeping obligations -Administrative and judicial review of CBP's decisions -CBP's auditing of importers' operations to determine compliance -Liquidated damages, penalties, and seizures -Government efforts to assure cargo security in aftermath of September 11.
Download or read book The American Printer written by and published by . This book was released on 1919 with total page 548 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 2021-06-18 with total page 484 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
