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Global Transfer Pricing Principles And Practice 4th Edition Nordic Edition
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Book Synopsis Global Transfer Pricing: Principles and Practice 4th Edition (Nordic Edition) by : Deloitte
Download or read book Global Transfer Pricing: Principles and Practice 4th Edition (Nordic Edition) written by Deloitte and published by Bloomsbury Professional. This book was released on 2020-02-27 with total page 328 pages. Available in PDF, EPUB and Kindle. Book excerpt: Now in its fourth edition, Global Transfer Pricing: Principles and Practices continues to provide a straightforward and accessible introduction to this complex and increasingly important area of business taxation. It offers readers an overall view of transfer pricing as it is practised today, including the 2017 changes to OECD transfer pricing guidance following the Base Erosion and Profit Shifting (BEPS) initiative. In addition to the theory of transfer pricing, this practical handbook explains how to implement transfer pricing models in global multinationals, how to monitor transactions to ensure compliance and how to create transfer pricing documentation. --
Book Synopsis Global Transfer Pricing: Principles and Practice by : John Henshall
Download or read book Global Transfer Pricing: Principles and Practice written by John Henshall and published by Bloomsbury Professional. This book was released on 2019-07-25 with total page 312 pages. Available in PDF, EPUB and Kindle. Book excerpt: Now in its fourth edition, Global Transfer Pricing: Principles and Practices continues to provide a straightforward and accessible introduction to this complex and increasingly important area of business taxation. It offers readers an overall view of transfer pricing as it is practised today, including the 2017 changes to OECD transfer pricing guidance following the Base Erosion and Profit Shifting (BEPS) initiative. In addition to the theory of transfer pricing, this practical handbook explains how to implement transfer pricing models in global multinationals, how to monitor transactions to ensure compliance and how to create transfer pricing documentation. This new edition includes: -An update on the implementation of BEPS recommendations, including artificial avoidance or permanent establishment status and prevention of treaty abuse -Implementation of transfer pricing documentation and country-by-country reporting -Additional case law references Chapter updates include: -Chapter 5 'Financing' has been updated to include commentary on the OECD discussion draft on transfer pricing aspects of financial transactions, including treasury function, guarantee fees and captive insurance -Chapter 7 'Profit Split' has been expanded to cover new guidance on profit split and the recent trend towards the use of this transfer pricing methodology -The 'UK' chapter includes new content on interest restriction rules and transfer pricing, penalties for non-compliance, rules governing the conduct of transfer pricing audits and also Brexit considerations -A new chapter has been added on 'The Attribution of Profits to Permanent Establishments' to cover Articles 7 and 9 of the OECD Model Tax Treaty
Book Synopsis Global Transfer Pricing by : Deloitte
Download or read book Global Transfer Pricing written by Deloitte and published by Bloomsbury Professional. This book was released on 2003-01-01 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: Written by an expert team, this title comprehensively outlines the general principles of transfer pricing and includes matrices of pricing. Contents includes: Introduction - what is it and why does it matter? OECD and legislative principles (theory) Tangible goods transactions Intra-group services Financing transactions Intangibles Global trading and the allocation of profits to permanent establishment Transfer pricing planning Documentation Eliminating double taxation Practical difficulties with arm's length pricing and TP planning
Book Synopsis Global Transfer Pricing by : Roy Donegan
Download or read book Global Transfer Pricing written by Roy Donegan and published by Bloomsbury Professional. This book was released on 2023-03-02 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Now in its fifth edition, Global Transfer Pricing: Principles and Practices continues to provide a straightforward and accessible introduction to this complex and increasingly important area of business taxation.It offers readers an overall view of transfer pricing as it is practised today. In addition to the theory of transfer pricing, this practical handbook explains how to implement transfer pricing models in global multinationals, how to monitor transactions to ensure compliance and how to create transfer pricing documentation.The transfer pricing environment has evolved significantly since publication of the previous edition - changes include Brexit, COVID-19, guidance on financial transactions and IBOR. All chapters have been updated in line with recent developments. Specific updates for this new edition include:- Chapter 5 updated to include OECD Transfer Pricing Guidance on Financial Transactions published in February 2020, practical application of the new guidance and IBOR transition- Chapter 6 now includes case law update on intangibles transfer pricing- Chapter 9 updated to cover HMRC consultation November 2021, Master file, local file and summary audit trail document and International Dealing Schedule kept under HMRC review- Chapter 10 updated with significant changes including practical relevance of operational transfer pricing for businesses and technology update- Chapter 12 to cover Brexit considerations and COVID-19 transfer pricing update
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.
Book Synopsis Global Transfer Pricing Solutions by : Katherine Dimancescu
Download or read book Global Transfer Pricing Solutions written by Katherine Dimancescu and published by Worldtrade Executive. This book was released on 2007 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This text discusses what the new era of global tax enforcement and administration means for multinational companies, how it will affect crossborder tax planning, and what steps corporate tax departments can take to manage compliance and risk both globally and locally.
Book Synopsis Transfer Pricing and Multinational Enterprises by : OECD
Download or read book Transfer Pricing and Multinational Enterprises written by OECD and published by OECD Publishing. This book was released on 1979-06-01 with total page 107 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.
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
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.
Book Synopsis Global Transfer Pricing Solutions by : Judy S. Kuan
Download or read book Global Transfer Pricing Solutions written by Judy S. Kuan and published by WorldTrade Executive, Inc.. This book was released on 2004-11 with total page 346 pages. Available in PDF, EPUB and Kindle. Book excerpt: GLOBAL TRANSFER PRICING SOLUTIONS: 2004 covers the major transfer pricing regimes around the world with in-depth discussion and analysis of such topics as proactive transfer pricing management of post-merger integrations, e-commerce and intellectual property. This report was prepared by members of major law and accounting firms and senior international transfer pricing professionals at the largest multinationals. It covers a wide range of tools and techniques relevant to transfer pricing in Asia, Europe, Latin America, and North America.
Book Synopsis Practical Guide to U.S. Transfer Pricing by : William H. Byrnes
Download or read book Practical Guide to U.S. Transfer Pricing written by William H. Byrnes and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The new 4th Edition of Practical Guide to U.S. Transfer Pricing continues to be the authoritative legal treatise for tax counsel, tax authorities, the judiciary, and policy makers. The 4th Edition is fully revised with several new chapters, over 2,000 pages of analyses and practice notes, 47 chapters divided over six parts. Part I: U.S. regulatory analysis, application of transfer pricing methods, and jurisprudence; Part II: OECD; Part III: United Nations; Part IV: European Union; Part V: Industry topics; and Part VI: Country practice and tax risk management.Professor Byrnes brings together 50 of the industry's eminent transfer pricing counsel, economists, and financial accountants to provide a comprehensive two-volume "go-to" resource for tax risk management.Within the first 29 chapters, the U.S. Treasury regulations and jurisprudence are analyzed from an advisory perspective, including chapters on the transfer pricing methods, documentation and examination, advance pricing agreements and mutual assistance, litigation, state issues, and customs. A chapter is dedicated to analyzing the transfer pricing aspects of each step of a U.S. business restructuring.The next six chapters of Part II address the OECD's approach to transfer pricing because many OECD member as well as nonmember countries refer to the OECD Transfer Pricing Guidelines as authoritative or persuasive. The U.S. Treasury refers to the OECD Guidelines for purposes of mutual agreement procedures between competent authorities of treaty partners. These chapters include an exemplary application of value chain analysis, digitalization's impact on transfer pricing compliance, and hybrid rules interaction with transfer pricing.Part III is reserved for future chapters analyzing the UN Transfer Pricing Manual and UN transfer pricing guidance for extractive industries because many subscribers have operations in developing economies. Part VI includes a chapter on the impact of EU State Aid cases on APAs. Part V includes nine industry specific chapters: two risk management chapters, five chapters for financial services topics, and two chapters providing case studies to examine the global value chain of an industry. Part VI contains two country chapters analyzing the national transfer pricing regulations and practice of Brazil and India. Parts II through Part VI will expand each year to include further analysis and case study chapters.
Book Synopsis Fundamentals of Transfer Pricing by : Michael Lang
Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2019-01-03 with total page 500 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.
Book Synopsis 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 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.
Book Synopsis Transfer Pricing Handbook by : Robert Feinschreiber
Download or read book Transfer Pricing Handbook written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2012-08-03 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: Learn OECD guidance on business taxation in multiple countries A business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying more in taxes that the share of profit it generates. The Organisation for Economic Co-operation and Development (OECD) seeks to reduce the risk of business taxation in multiple countries. Transfer Pricing Handbook explores how countries can apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. It is the ultimate comprehensive guide for companies doing business globally. Helps companies properly price their goods and services for global markets Provides defenses for transfer pricing audits Provides standards for creating comparables that multijurisdictional tax administrations will accept Guides documentation requirements and timing issues If you're doing business in more than one country, Transfer Pricing Handbook is a must-have, essential guide for simplifying OECD regulations for your global company.
Book Synopsis Transfer Pricing in Action by : Aydin Hayri
Download or read book Transfer Pricing in Action written by Aydin Hayri and published by Kluwer Law International. This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an overview of the abstract theory of transfer pricing and its everyday practice. It is an extended hypothetical case history, presented in narrative style illustrated with graphics. It gives 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. The book contains the following chapters: (1) MSell - a fast growth company considers corporate taxation; (2) Big tax proposal, rejected; (3) The inevitable growing pains, and state tax planning ; (4) Going international, the Canadian expansion; (5) Further expansion: the United Kingdom and greater Europe; (6) The European distributors and a surprising development, or two; (7) Services transactions: US headquarter and support services for Europe; (8) Intangibles licensing transaction, with gusto; (9) Intra-European structuring; (10) Sourcing; (11) Branding, and a new CEO; (12) Planning for a new global business model; (13) Designing and implementing the new global business model; (14) A (rather unpleasant) Thanksgiving surprise; and a timeline figure.
Book Synopsis Tax Director's Guide to International Transfer Pricing: 2010 Edition by : Brian E. Andreoli
Download or read book Tax Director's Guide to International Transfer Pricing: 2010 Edition written by Brian E. Andreoli and published by Gbis, Incorporated. This book was released on 2010-06 with total page 560 pages. Available in PDF, EPUB and Kindle. Book excerpt: More than fifty of the world's leading transfer pricing professionals offer their advice and insights on how to navigate complex issues, including: When is an APA Advantageous?, Understanding the New U.S. Services Regulations, Transfer Pricing Implications of Reorganizations, Valuing Intangibles Under Cost Sharing Arrangements, and How to Apply the Best Method Rule. The book also provides a country-by-country review of transfer pricing laws in seventeen major economies, addressing questions such as: What transfer pricing methods are accepted?, Do the local tax authorities favor a given method?, What dispute resolution mechanisms are available?, Are APAs allowed and, if so, what are the rules, To what extent are international guidelines followed?, How is the acceptability of comparables determined?, What are the documentation requirements?, and How are non-compliance penalties calculated? This newly updated 2010 Edition builds on the success of the original Tax Director's Guide to International Transfer Pricing, which has been relied upon by international tax professionals around the world. The articles in this new edition reflect the intense competition for tax dollars among various countries in a time of global recession, during which many tightened their transfer pricing rules and increased enforcement. The majority of the articles contain significant substantive updates. In addition, the book includes five new country overview articles discussing transfer pricing rules and practices in Australia, Hong Kong, India, Japan, and Singapore. This edition also includes an entirely new China section in response to the major transfer pricing legislation that recently went into effect, as well as a new article on supply chain management. In-house tax specialists and outside advisors alike will find this book to be an invaluable resource in their efforts to manage global tax exposure.
