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Author : Albert Frakes
Publisher :
ISBN 13 :
Total Pages : 61 pages
Book Rating : 4.:/5 (843 download)
Download or read book An Analysis of the Transfer Pricing Problem written by Albert Frakes and published by . This book was released on 1964 with total page 61 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Robert G. Eccles
Publisher : Free Press
ISBN 13 :
Total Pages : 376 pages
Book Rating : 4.:/5 (321 download)
Download or read book The Transfer Pricing Problem written by Robert G. Eccles and published by Free Press. This book was released on 1985 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt: Author explores the transfer pricing policies. On the beginning, he identifies the elements of administrative process that are crucial for managing the transfer pricing in corporate practice. Furthermore, he examines the management challenges of the most common transfer pricing policies. Finally, he presents general framework for strategy implementation that is designed to help managers to analyse their own company transfer pricing practices.
Author : Elizabeth King
Publisher : Springer Science & Business Media
ISBN 13 : 0387781838
Total Pages : 199 pages
Book Rating : 4.3/5 (877 download)
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.
Author : Eduardo Baistrocchi
Publisher : Cambridge University Press
ISBN 13 : 1139916289
Total Pages : 975 pages
Book Rating : 4.1/5 (399 download)
Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Author : David Otley and Kenneth Merchant Clive Emmanuel
Publisher : Springer
ISBN 13 : 1489971386
Total Pages : 689 pages
Book Rating : 4.4/5 (899 download)
Download or read book Readings in Accounting for Management Control written by David Otley and Kenneth Merchant Clive Emmanuel and published by Springer. This book was released on 2013-12-19 with total page 689 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : James R. Hines
Publisher :
ISBN 13 :
Total Pages : 54 pages
Book Rating : 4.3/5 ( download)
Download or read book The Transfer Pricing Problem written by James R. Hines and published by . This book was released on 1990 with total page 54 pages. Available in PDF, EPUB and Kindle. Book excerpt: Section 1 introduces the material. Section 2 of this paper describes the transfer pricing problem and some solutions that have been proposed in the past. Section 3 offers a different solution and demonstrates that it supports an efficient allocation of resources. Section 4 briefly discusses some of the complications that arise in practice, analyzes methods governments have employed to address this problem, and argues that the solution corresponds to concepts of income division that governments have tried to employ in broader contexts.
Author : James R. Hines (jr.)
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (848 download)
Download or read book The Transfer Pricing Problem: where the Profits are written by James R. Hines (jr.) and published by . This book was released on 1990 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 940352393X
Total Pages : 312 pages
Book Rating : 4.4/5 (35 download)
Download or read book Transfer Pricing Developments Around the World 2020 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2020-09-28 with total page 312 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 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 : Michelle Markham
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041123687
Total Pages : 360 pages
Book Rating : 4.0/5 (411 download)
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.
Author : David F. Bradford
Publisher :
ISBN 13 :
Total Pages : 35 pages
Book Rating : 4.:/5 (163 download)
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
Author : Savita Abhijit Sahay
Publisher :
ISBN 13 :
Total Pages : 228 pages
Book Rating : 4.:/5 (34 download)
Download or read book Studies in the Theory of Transfer Pricing written by Savita Abhijit Sahay and published by . This book was released on 1997 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Robert T. Cole
Publisher : Aspen Publishers
ISBN 13 :
Total Pages : 1302 pages
Book Rating : 4.0/5 ( download)
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.
Author : James R. Hines (jr.)
Publisher :
ISBN 13 :
Total Pages : 34 pages
Book Rating : 4.:/5 (848 download)
Download or read book The Transfer Pricing Problem: where the Profits are written by James R. Hines (jr.) and published by . This book was released on 1990 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : William S. Dittoe
Publisher :
ISBN 13 :
Total Pages : 130 pages
Book Rating : 4.:/5 (843 download)
Download or read book A Look at the Transfer Pricing Problem for U.S. Multinational Corporations written by William S. Dittoe and published by . This book was released on 1981 with total page 130 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264169466
Total Pages : 110 pages
Book Rating : 4.2/5 (641 download)
Download or read book Dealing Effectively with the Challenges of Transfer Pricing written by OECD and published by OECD Publishing. This book was released on 2012-01-18 with total page 110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report addresses the practical administration of transfer pricing programmes by tax administrations.
Author : Business International Corporation
Publisher :
ISBN 13 :
Total Pages : 212 pages
Book Rating : 4.:/5 (318 download)
Download or read book International Transfer Pricing written by Business International Corporation and published by . This book was released on 1991 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: A comprehensive guide to corporate practices in internal control and tax compliance. Included are case studies of how firms in a variety of industries approach transfer pricing.
Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403517247
Total Pages : 484 pages
Book Rating : 4.4/5 (35 download)
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.
