Empirical Study Of Transfer Pricing And The Intangibles

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Empirical Study of Transfer Pricing and the Intangibles

Author : Emmanuel Shola Ayeni
Publisher :
ISBN 13 : 9781718191853
Total Pages : 320 pages
Book Rating : 4.1/5 (918 download)

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Book Synopsis Empirical Study of Transfer Pricing and the Intangibles by : Emmanuel Shola Ayeni

Download or read book Empirical Study of Transfer Pricing and the Intangibles written by Emmanuel Shola Ayeni and published by . This book was released on 2018-08-19 with total page 320 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is an ancient phenomenon with far more consequence in today's business environment. A significant volume of global trade nowadays consists of international transfers of tangibles: goods and services, capital (such as money) and intangibles (such as intellectual property) within an MNE group; such transfers are called "intra-group" transactions which continued to grow exponentially in all international transactions. When these transfers take place, the values of those transfers become significant both to the MNEs and various tax authorities. For tangible goods and services, the values are easily ascertainable and thus, making the transfer pricing methodology less arduous and the framework easily acceptable between the stakeholders. For intangibles, however, the valuation is more complex and the difficulties attendant to transfer pricing are more contentious. It is against this backdrop that this book examines the complexity of transfer pricing of intangibles and the attendant difficulties of the methodology to determining the arm's length principle of any transaction involving intangible assets. This study is an attempt to find ways to placate the frictions between tax authorities and multinational enterprises (MNEs) that Transfer Pricing of intangibles often brings. The objectives of this study are four-fold. First, it compares case laws from the United States and selected jurisdictions - - the United Kingdom, Australia, New Zealand, Italy, and Germany to identify the disparities and similarities of legal opinions on Transfer Pricing of intangibles. Second, it identifies any uniformity in the judicial interpretation of arm's length pricing of intangible assets. Third, it examines the focus of conflicts between tax authorities and multinational enterprises. Fourth, it explores any existing legal solutions that may help placate, or altogether, avoid the frictions between the stakeholders while formulating alternative dispute resolutions. The book provides empirical evidence of Transfer Pricing practices and the attendant difficulties by comparing the judicial review of the conflicts between the stakeholders in the United States, United Kingdom, Australia, Italy, and Germany to show the relative effectiveness, or lack thereof, of judicial intervention. Specifically, the book underscores the judicial uncertainty in the resolution of transfer pricing issue relating to intangibles and explores the use of augmented APAs as alternative resolution of Transfer Pricing issues between the stakeholders.

Transfer Pricing of Intangibles

Author : Emmanuel Shola Ayeni, PhD
Publisher :
ISBN 13 :
Total Pages : 338 pages
Book Rating : 4.6/5 (862 download)

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Book Synopsis Transfer Pricing of Intangibles by : Emmanuel Shola Ayeni, PhD

Download or read book Transfer Pricing of Intangibles written by Emmanuel Shola Ayeni, PhD and published by . This book was released on 2020-09-14 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is an ancient phenomenon with far more consequence in today's business environment. A significant volume of global trade nowadays consists of international transfers of tangibles: goods and services, capital (such as money) and intangibles (such as intellectual property) within an MNE group; such transfers are called "intra-group" transactions which continued to grow exponentially in all international transactions. When these transfers take place, the values of those transfers become significant both to the MNEs and various tax authorities. For tangible goods and services, the values are easily ascertainable and thus, making the transfer pricing methodology less arduous and the framework easily acceptable between the stakeholders. For intangibles, however, the valuation is more complex and the difficulties attendant to transfer pricing are more contentious. It is against this backdrop that this book examines the complexity of transfer pricing of intangibles and the attendant difficulties of the methodology to determining the arm's length principle of any transaction involving intangible assets. This study is an attempt to find ways to placate the frictions between tax authorities and multinational enterprises (MNEs) that Transfer Pricing of intangibles often brings. The objectives of this study are four-fold. First, it compares case laws from the United States and selected jurisdictions - - the United Kingdom, Australia, New Zealand, Italy, and Germany to identify the disparities and similarities of legal opinions on Transfer Pricing of intangibles. Second, it identifies any uniformity in the judicial interpretation of arm's length pricing of intangible assets. Third, it examines the focus of conflicts between tax authorities and multinational enterprises. Fourth, it explores any existing legal solutions that may help placate, or altogether, avoid the frictions between the stakeholders while formulating alternative dispute resolutions. The book provides empirical evidence of Transfer Pricing practices and the attendant difficulties by comparing the judicial review of the conflicts between the stakeholders in the United States, United Kingdom, Australia, Italy, and Germany to show the relative effectiveness, or lack thereof, of judicial intervention. Specifically, the book underscores the judicial uncertainty in the resolution of transfer pricing issue relating to intangibles and explores the use of augmented APAs as alternative resolution of Transfer Pricing issues between the stakeholders.

Empirical Study of Transfer Pricing and the Intangibles

Author : Emmanuel Shola Ayeni Ph D
Publisher :
ISBN 13 :
Total Pages : 338 pages
Book Rating : 4.6/5 (847 download)

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Book Synopsis Empirical Study of Transfer Pricing and the Intangibles by : Emmanuel Shola Ayeni Ph D

Download or read book Empirical Study of Transfer Pricing and the Intangibles written by Emmanuel Shola Ayeni Ph D and published by . This book was released on 2020-09-12 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is an ancient phenomenon with far more consequence in today's business environment. A significant volume of global trade nowadays consists of international transfers of tangibles: goods and services, capital (such as money) and intangibles (such as intellectual property) within an MNE group; such transfers are called "intra-group" transactions which continued to grow exponentially in all international transactions. When these transfers take place, the values of those transfers become significant both to the MNEs and various tax authorities. For tangible goods and services, the values are easily ascertainable and thus, making the transfer pricing methodology less arduous and the framework easily acceptable between the stakeholders. For intangibles, however, the valuation is more complex and the difficulties attendant to transfer pricing are more contentious. It is against this backdrop that this book examines the complexity of transfer pricing of intangibles and the attendant difficulties of the methodology to determining the arm's length principle of any transaction involving intangible assets. This study is an attempt to find ways to placate the frictions between tax authorities and multinational enterprises (MNEs) that Transfer Pricing of intangibles often brings. The objectives of this study are four-fold. First, it compares case laws from the United States and selected jurisdictions - - the United Kingdom, Australia, New Zealand, Italy, and Germany to identify the disparities and similarities of legal opinions on Transfer Pricing of intangibles. Second, it identifies any uniformity in the judicial interpretation of arm's length pricing of intangible assets. Third, it examines the focus of conflicts between tax authorities and multinational enterprises. Fourth, it explores any existing legal solutions that may help placate, or altogether, avoid the frictions between the stakeholders while formulating alternative dispute resolutions. The book provides empirical evidence of Transfer Pricing practices and the attendant difficulties by comparing the judicial review of the conflicts between the stakeholders in the United States, United Kingdom, Australia, Italy, and Germany to show the relative effectiveness, or lack thereof, of judicial intervention. Specifically, the book underscores the judicial uncertainty in the resolution of transfer pricing issue relating to intangibles and explores the use of augmented APAs as alternative resolution of Transfer Pricing issues between the stakeholders.

The Transfer Pricing of Intangibles

Author : Michelle Markham
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041123687
Total Pages : 360 pages
Book Rating : 4.0/5 (411 download)

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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.

Transfer Pricing and Intangibles

Author : Michael Lang
Publisher : Linde Verlag GmbH
ISBN 13 : 370941010X
Total Pages : 176 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Transfer Pricing and Intangibles by : Michael Lang

Download or read book Transfer Pricing and Intangibles written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2019-04-11 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.

Income Shifting from Transfer Pricing

Author : Michael McDonald
Publisher : CreateSpace
ISBN 13 : 9781505389920
Total Pages : 40 pages
Book Rating : 4.3/5 (899 download)

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Book Synopsis Income Shifting from Transfer Pricing by : Michael McDonald

Download or read book Income Shifting from Transfer Pricing written by Michael McDonald and published by CreateSpace. This book was released on 2015-01-01 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: The paper updates, modifies, and extends research by Grubert (2003) to investigate income shifting from intercompany transfer pricing. The analysis is based on theoretical and regression models developed in Grubert (2003). The models are modified slightly to capture the effects of "real" intercompany tangible, intangible, and services transactions (as opposed to interest 'income stripping' through intercompany or interbranch debt), and extended to incorporate data relating to cost sharing arrangements. Although some caution is required in interpreting the transfer pricing implications from the regression results, the empirical analysis generally supports concerns about potential non-arm's length income shifting under current transfer pricing rules.

Transfer Pricing in Multinational Corportions

Author : Linda Ann Mandel
Publisher :
ISBN 13 :
Total Pages : 38 pages
Book Rating : 4.:/5 (299 download)

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Book Synopsis Transfer Pricing in Multinational Corportions by : Linda Ann Mandel

Download or read book Transfer Pricing in Multinational Corportions written by Linda Ann Mandel and published by . This book was released on 1985 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Transfer Pricing

Author : Morten Jakobsen
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (464 download)

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Book Synopsis Transfer Pricing by : Morten Jakobsen

Download or read book Transfer Pricing written by Morten Jakobsen and published by . This book was released on 2001 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Intangibles in the World of Transfer Pricing

Author : Björn Heidecke
Publisher : Springer
ISBN 13 : 9783319733319
Total Pages : 725 pages
Book Rating : 4.7/5 (333 download)

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Book Synopsis Intangibles in the World of Transfer Pricing by : Björn Heidecke

Download or read book Intangibles in the World of Transfer Pricing written by Björn Heidecke and published by Springer. This book was released on 2021-03-10 with total page 725 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intangible assets are becoming increasingly important as value drivers for multinational companies. It is a strategic question how to allocate intangibles within the multinational corporation. It needs to be defined by whom and under which conditions they can be utilized. Typical IP migration models such as licensing, joint development and transferring are becoming a focal point within tax audits across the globe. Hence,defining an intangibles system that fulfils the tax requirements is of utmost strategic importance for multinational corporations. A central question is how to value intangibles in line with the arm’s length principle as is required internationally for transfer pricing purposes. Edited by leading transfer pricing and valuation experts in Europe, this comprehensive book offers practitioners an effective road map for identifying, valuing and implementing intangibles for transfer pricing purposes under consideration of both the OECD and local perspectives. It is therefore a must-have book for transfer pricing and valuation practitioners on all levels of experience. The book starts with an introduction to the role of intangibles in the world of transfer pricing including typical intangibles migration models. It describes common intangible assets across all types of industries, including e.g. automotive, consumer goods and software.Using several numerical examples, the book then covers state-of-the-art valuation methods including how to apply these methods in practice in a way consistent with the OECD Transfer Pricing Guidelines. The different country chapters written by local experts provide country-specific guidance on the legal framework concerning intangible assets from a transfer pricing and valuation perspective. Finally, the book covers practical advice on the implementation of an intangible assets system. This book offers invaluable guidance to practitioners seeking tools to apply the arm’s length principle in the world of intangibles.

International Transfer Pricing

Author : Monica Boos
Publisher :
ISBN 13 :
Total Pages : 288 pages
Book Rating : 4.3/5 ( download)

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Book Synopsis International Transfer Pricing by : Monica Boos

Download or read book International Transfer Pricing written by Monica Boos and published by . This book was released on 2003 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: The valuation of intangibles as they are transferred from country to country but within multinational enterprise networks is major issue in taxation.

Transfer Pricing Methods

Author : Robert Feinschreiber
Publisher : John Wiley & Sons
ISBN 13 : 0471651230
Total Pages : 338 pages
Book Rating : 4.4/5 (716 download)

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Book Synopsis Transfer Pricing Methods by : Robert Feinschreiber

Download or read book Transfer Pricing Methods written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2004-03-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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

Decoding Transfer Pricing for Selling Functions

Author : Rahul K Mitra
Publisher :
ISBN 13 : 9389859743
Total Pages : 111 pages
Book Rating : 4.3/5 (898 download)

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Book Synopsis Decoding Transfer Pricing for Selling Functions by : Rahul K Mitra

Download or read book Decoding Transfer Pricing for Selling Functions written by Rahul K Mitra and published by . This book was released on 2020-08-25 with total page 111 pages. Available in PDF, EPUB and Kindle. Book excerpt: Are some of the theories of OECD and UN around marketing intangibles sacrosanct? The same have been countered through qualitative and quantitative arguments. Quantitative arguments are based upon real life scenarios, with reference to statistical analyses on selected empirical data. Genesis of litigation around marketing intangibles analysed, along with solutions. Concept of royalties for licensed manufacturers explained in the context of regulatory regime of India. Practical solutions provided on harmonisation of transfer pricing and customs duty regulations in complex cases. Concept of attribution of profits to dependent agency permanent establishments explained, with reference to Berry Ratio. Foreword by Dr. Raffalle Dr. Raffaele Petruzzi & Dr. Alfred Storck Professors of Vienna University of Economics and Business

An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property

Author : Melanie Keller
Publisher : GRIN Verlag
ISBN 13 : 3668021937
Total Pages : 32 pages
Book Rating : 4.6/5 (68 download)

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Book Synopsis An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property by : Melanie Keller

Download or read book An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property written by Melanie Keller and published by GRIN Verlag. This book was released on 2015-07-24 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bachelor Thesis from the year 2015 in the subject Economics - International Economic Relations, Management Center Innsbruck, language: English, abstract: Due to increased globalisation over the last years and enhanced activities of multinational enterprises (MNEs), intra-firm trade has become more and more important. Intra-firm trade is estimated to constitute about one third of the global trade; and about 50% of all exports within the member states of the Organisation for Economic Co-operation and Development (OECD) are intra-firm exports. In order to determine the expenses and revenues for the associated companies, transfer prices (TP) have to be set for the respective goods of intra-group transfers (Organisation for Economic Co-operation and Development [OECD]). Intra-group transfers can be defined as the transaction of tangible or intangible property from one entity of a MNE to another entity, considered as sale and “may apply to departments, divisions, subsidiaries, or affiliate business units” . A TP therefore is the internal monetary value im-posed on goods, services or unmanufactured material that is transferred within a MNE group. According to the OECD (2010) intra-firm transfers are likewise de-fined as controlled transactions (i.e., transactions between two associated enterprises).

A missing link in the analysis of global value chains: cross-border flows of intangible assets, taxation and related measurement implications

Download A missing link in the analysis of global value chains: cross-border flows of intangible assets, taxation and related measurement implications PDF Online Free

Author : World Intellectual Property Organization
Publisher : WIPO
ISBN 13 :
Total Pages : 60 pages
Book Rating : 4./5 ( download)

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Book Synopsis A missing link in the analysis of global value chains: cross-border flows of intangible assets, taxation and related measurement implications by : World Intellectual Property Organization

Download or read book A missing link in the analysis of global value chains: cross-border flows of intangible assets, taxation and related measurement implications written by World Intellectual Property Organization and published by WIPO. This book was released on 2017 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt: Understanding cross-border flows of disembodied knowledge, often associated with intellectual property (IP), is essential to analyzing how modern economies operate. This paper documents how available data to document these IP flows are distorted by various factors, including tax planning by multinational enterprises. It finds that tax-induced mismeasurement could be more than 35%, and greater for individual countries particularly high-tax-rate countries.

Transfer Pricing and Valuation in Corporate Taxation

Author : Elizabeth King
Publisher : Springer Science & Business Media
ISBN 13 : 0306482185
Total Pages : 294 pages
Book Rating : 4.3/5 (64 download)

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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.

U.S. Transfer Pricing Sourcebook

Author : Amanda Johnson
Publisher : WorldTrade Executive, Inc.
ISBN 13 : 9781893323698
Total Pages : 124 pages
Book Rating : 4.3/5 (236 download)

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Book Synopsis U.S. Transfer Pricing Sourcebook by : Amanda Johnson

Download or read book U.S. Transfer Pricing Sourcebook written by Amanda Johnson and published by WorldTrade Executive, Inc.. This book was released on 2005-03 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: U.S. TRANSFER PRICING SOURCEBOOK is a single-volume report designed to advise international finance professionals on the cutting edge tools and techniques being developed and applied by leading consultants. This sourcebook provides strategies on Intercompany Sales, Intercompany Service transactions, Cross-Border licensing, and Cost Sharing agreements.

Critical Concerns in Transfer Pricing and Practice

Author : Wagdy M. Abdallah
Publisher : Bloomsbury Publishing USA
ISBN 13 : 0313053685
Total Pages : 272 pages
Book Rating : 4.3/5 (13 download)

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Book Synopsis Critical Concerns in Transfer Pricing and Practice by : Wagdy M. Abdallah

Download or read book Critical Concerns in Transfer Pricing and Practice written by Wagdy M. Abdallah and published by Bloomsbury Publishing USA. This book was released on 2004-07-30 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: For multinational corporations (MNCs), there is arguably no more important operational function that affects all areas of manufacturing, marketing, management, and finance as international transfer pricing—the practicing of supplying products or services across borders from one part of the organization to another. Its complexity is compounded by the impact of e-commerce, speeding the flow of goods and services; intangible assets, such as intellectual property, whose value is difficult to quantify; and the activites of policymakers around the world to update their tax laws and regulations, in efforts to close loopholes that have historically encouraged tax avoidance. In Critical Concerns in Transfer Pricing Policy and Practice, Wagdy Abdallah provides an in-depth overview of these recent trends and developments, and considers their implications for the management of MNCs. In particular, he discusses methods for pricing transferred goods and services in the e-commerce era and analyzes the most recent regulation reforms in such countries as Germany, Mexico, Japan, Canada, the United Kingdom, the United States, and the Netherlands. Anticipating increased scrutiny of MNC transfer pricing practices from governments and other external stakeholders, Abdallah outlines a set of practical recommendations for creating a successful transfer pricing system that maximizes value for the company while remaining sensitive to local policies in all of the countries in which it operates.