Fundamentals Of Transfer Pricing

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Fundamentals of 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)

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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.

Fundamentals of Transfer Pricing

Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 904119021X
Total Pages : 500 pages
Book Rating : 4.0/5 (411 download)

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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.

Fundamentals of Transfer Pricing

Author : Michael Lang
Publisher :
ISBN 13 : 9789041189943
Total Pages : 0 pages
Book Rating : 4.1/5 (899 download)

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Book Synopsis Fundamentals of Transfer Pricing by : Michael Lang

Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by . This book was released on 2019 with total page 0 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. In analysing the 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.

Fundamentals of International Transfer Pricing in Law and Economics

Author : Wolfgang Schön
Publisher : Springer Science & Business Media
ISBN 13 : 3642259804
Total Pages : 306 pages
Book Rating : 4.6/5 (422 download)

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Book Synopsis Fundamentals of International Transfer Pricing in Law and Economics by : Wolfgang Schön

Download or read book Fundamentals of International Transfer Pricing in Law and Economics written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2012-02-15 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.

Fundamentals of Transfer Pricing

Author : Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403535202
Total Pages : 549 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Fundamentals of Transfer Pricing by : Raffaele Petruzzi

Download or read book Fundamentals of Transfer Pricing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2022-06-20 with total page 549 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing’s interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.

Practical Guide to U.S. Transfer Pricing

Author : Robert T. Cole
Publisher : Aspen Publishers
ISBN 13 :
Total Pages : 1302 pages
Book Rating : 4.0/5 ( download)

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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.

Introduction to Transfer Pricing

Author : Jerome Monsenego
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403514930
Total Pages : 281 pages
Book Rating : 4.4/5 (35 download)

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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.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264921915
Total Pages : 659 pages
Book Rating : 4.2/5 (649 download)

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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 659 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.

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.

The Fundamentals of U.S. Transfer Pricing

Author : Steve C. Wrappe
Publisher :
ISBN 13 : 9781639052912
Total Pages : 0 pages
Book Rating : 4.0/5 (529 download)

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Book Synopsis The Fundamentals of U.S. Transfer Pricing by : Steve C. Wrappe

Download or read book The Fundamentals of U.S. Transfer Pricing written by Steve C. Wrappe and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Introduction to Transfer Pricing

Author : Jerome Monsenego
Publisher :
ISBN 13 : 9789144092706
Total Pages : 163 pages
Book Rating : 4.0/5 (927 download)

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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.

Transfer Pricing in One Lesson

Author : Oliver Treidler
Publisher : Springer Nature
ISBN 13 : 3030250857
Total Pages : 145 pages
Book Rating : 4.0/5 (32 download)

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Book Synopsis Transfer Pricing in One Lesson by : Oliver Treidler

Download or read book Transfer Pricing in One Lesson written by Oliver Treidler and published by Springer Nature. This book was released on 2019-09-12 with total page 145 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm’s length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book’s content is applicable to a global context.

Fundamentals of Momentum, Heat, and Mass Transfer

Author : James R. Welty
Publisher :
ISBN 13 :
Total Pages : 828 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis Fundamentals of Momentum, Heat, and Mass Transfer by : James R. Welty

Download or read book Fundamentals of Momentum, Heat, and Mass Transfer written by James R. Welty and published by . This book was released on 1976 with total page 828 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Fundamentals of Transfer Pricing in Japan

Author : Karl Gruendel
Publisher :
ISBN 13 : 9789814228015
Total Pages : 129 pages
Book Rating : 4.2/5 (28 download)

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Book Synopsis Fundamentals of Transfer Pricing in Japan by : Karl Gruendel

Download or read book Fundamentals of Transfer Pricing in Japan written by Karl Gruendel and published by . This book was released on 2007 with total page 129 pages. Available in PDF, EPUB and Kindle. Book excerpt:

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264265120
Total Pages : 608 pages
Book Rating : 4.2/5 (642 download)

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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 608 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.

Transfer Pricing in Action

Author : Althea Azeff
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041147004
Total Pages : 573 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Transfer Pricing in Action by : Althea Azeff

Download or read book Transfer Pricing in Action written by Althea Azeff and published by Kluwer Law International B.V.. This book was released on 2013-07-01 with total page 573 pages. Available in PDF, EPUB and Kindle. Book excerpt: Business tax strategy is at its most challenging when success ushers in the promise of major growth. At this ‘moment of truth’ the thorny special issues associated with international expansion loom over the fate of the company. These issues can be summarized in two words: transfer pricing. In this extended hypothetical case history, presented in narrative style with an abundance of graphic material, the authors lay bare the minutest details of transfer pricing planning and how the process engages and affects the ambitions, insights, and interactions of the group of business people and advisors involved. Because of this exposure to decision making and consulting dynamics, the reader gets a taste of the trade-off between ‘correctness’ and practicality. In fact, a more practical approach to the subject is hard to imagine. The book’s format, innovative in every way, finds plenty of room to define every term, cite every source, and describe every opportunity or pitfall affecting the tax aspects of such processes as moving into new jurisdictions, restructuring operations to create regional or global centres of excellence, or changing supply chains. Scores of information-packed tables, graphs, flowcharts, and other illustrations – often in the form of slide presentation screens or ‘real-world boxes’ – enhance the in-depth discussion of such aspects of international tax planning as the following (among much else): choice of tax status; investors and control; licensing and intellectual property issues; accounting methods; recruiting foreign personnel; and tax audits by revenue authorities. In a business environment where transfer pricing has emerged as the most dynamic area of international taxation, following extensive legislative activity and rulemaking, this remarkable book bridges the abstract theory of transfer pricing and its everyday practice in a very accessible way. No other book on the subject is so practical or so down to earth. Lawyers and other professionals in international taxation and tax law will find it enormously appealing, informative, and useful.

The Taxation of Permanent Establishments

Author : Sven Hentschel
Publisher : Springer Nature
ISBN 13 : 3658340002
Total Pages : 521 pages
Book Rating : 4.6/5 (583 download)

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Book Synopsis The Taxation of Permanent Establishments by : Sven Hentschel

Download or read book The Taxation of Permanent Establishments written by Sven Hentschel and published by Springer Nature. This book was released on 2021-06-26 with total page 521 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.