Guide To International Transfer Pricing

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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.

Guide to International Transfer Pricing

Author : A. Michael Heimert
Publisher :
ISBN 13 : 9789041138972
Total Pages : 0 pages
Book Rating : 4.1/5 (389 download)

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Book Synopsis Guide to International Transfer Pricing by : A. Michael Heimert

Download or read book Guide to International Transfer Pricing written by A. Michael Heimert and published by . This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The pricing of goods and services within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of tax revenue overseas, making the issue one of great importance to multinational corporations. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide's relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions."

Guide to International Transfer Pricing

Author : Dr A. Michael Heimert
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403501715
Total Pages : 1290 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Guide to International Transfer Pricing by : Dr A. Michael Heimert

Download or read book Guide to International Transfer Pricing written by Dr A. Michael Heimert and published by Kluwer Law International B.V.. This book was released on 2018-10-26 with total page 1290 pages. Available in PDF, EPUB and Kindle. Book excerpt: The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.

Guide to International Transfer Pricing

Author : Duff & Phelps
Publisher : Kluwer Law International
ISBN 13 : 9789041190499
Total Pages : 0 pages
Book Rating : 4.1/5 (94 download)

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Book Synopsis Guide to International Transfer Pricing by : Duff & Phelps

Download or read book Guide to International Transfer Pricing written by Duff & Phelps and published by Kluwer Law International. This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: "In this book, global practitioners address both the general issues that surround transfer pricing, including the OECD's fifteen-item base erosion and profit shifting plan and the specific rules and issues that any company must concern itself with in various jurisdictions around the world. Tax authorities around the globe are increasingly scrutinizing the intercompany pricing practices of taxpayers and enacting rules and regulations to ensure an appropriate allocation of income among the various tax jurisdictions in which a multinational company operates. In addition, a growing number of tax authorities have established documentation requirements to demonstrate appropriate transfer pricing policies, with penalty provisions for non-compliance."--

Guide to International Transfer Pricing

Author : Ceteris, Inc
Publisher :
ISBN 13 : 9789041131218
Total Pages : 0 pages
Book Rating : 4.1/5 (312 download)

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Book Synopsis Guide to International Transfer Pricing by : Ceteris, Inc

Download or read book Guide to International Transfer Pricing written by Ceteris, Inc and published by . This book was released on 2010 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication will be shortly available online at: www.kluwerlawonline.com The pricing of goods and services within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious

Transfer Pricing International

Author : Robert Feinschreiber
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (133 download)

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Book Synopsis Transfer Pricing International by : Robert Feinschreiber

Download or read book Transfer Pricing International written by Robert Feinschreiber and published by . This book was released on 2000 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

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

International Transfer Pricing

Author : Mark Atkinson
Publisher : Ft Press
ISBN 13 : 9780273638100
Total Pages : 284 pages
Book Rating : 4.6/5 (381 download)

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Book Synopsis International Transfer Pricing by : Mark Atkinson

Download or read book International Transfer Pricing written by Mark Atkinson and published by Ft Press. This book was released on 1999 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt: The rules applying to international transfer pricing are changing radically. Failure to comply could lead to severe tax penalties, whilst planning now will save you time and money. What are the implications of the new legislation and how can you comply? International Transfer Pricing offers you the essential guidance you need on planning an effective Transfer Pricing strategy. This report explains the implications of the changes in legislation for multinational companies and details what you can do now to prepare. If your company operates in a multinational environment, then this report will be of practical relevance to you.

Guide to International Transfer Pricing

Author : Ceteris
Publisher :
ISBN 13 : 9789041136596
Total Pages : 0 pages
Book Rating : 4.1/5 (365 download)

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Book Synopsis Guide to International Transfer Pricing by : Ceteris

Download or read book Guide to International Transfer Pricing written by Ceteris and published by . This book was released on 2012 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Also available online at www.kluwerlawonline.com The pricing of goods and services within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of tax revenue overseas, making the issue one of great importance to multinational corporations. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide's relevance is further enhanced by the inclusion of 11 country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.

Tax Director's Guide to International Transfer Pricing

Author : Brian E. Andreoli
Publisher : Gbis, Incorporated
ISBN 13 : 9781602310018
Total Pages : 404 pages
Book Rating : 4.3/5 (1 download)

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Book Synopsis Tax Director's Guide to International Transfer Pricing by : Brian E. Andreoli

Download or read book Tax Director's Guide to International Transfer Pricing written by Brian E. Andreoli and published by Gbis, Incorporated. This book was released on 2008 with total page 404 pages. Available in PDF, EPUB and Kindle. Book excerpt: Forty-two of the world's leading transfer pricing professionals offer their advice and insights on how to navigate complex issues, and provide a country-by-country review of transfer pricing laws in a dozen major economies.

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.

Tax Director's Guide to International Transfer Pricing: 2010 Edition

Author : Brian E. Andreoli
Publisher : Gbis, Incorporated
ISBN 13 : 9781602310049
Total Pages : 560 pages
Book Rating : 4.3/5 (1 download)

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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.

Intercompany Agreements for Transfer Pricing Compliance

Author : Paul Sutton
Publisher :
ISBN 13 : 9781912687183
Total Pages : 146 pages
Book Rating : 4.6/5 (871 download)

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Book Synopsis Intercompany Agreements for Transfer Pricing Compliance by : Paul Sutton

Download or read book Intercompany Agreements for Transfer Pricing Compliance written by Paul Sutton and published by . This book was released on 2019-03-11 with total page 146 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a practical resource for finance, tax and transfer pricing professionals, and for anyone involved in designing, implementing, maintaining or reviewing intercompany agreements for multinational groups.

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.

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.

Practical Guide to U.S. Taxation of International Transactions

Author : Michael S. Schadewald
Publisher :
ISBN 13 : 9780808040842
Total Pages : 0 pages
Book Rating : 4.0/5 (48 download)

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Book Synopsis Practical Guide to U.S. Taxation of International Transactions by : Michael S. Schadewald

Download or read book Practical Guide to U.S. Taxation of International Transactions written by Michael S. Schadewald and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Taxation of International Transactions provides readers with a practical command of the tax issues raised by international transactions and how those issues are resolved by U.S. tax laws. The book emphasizes those areas generally accepted to be essential to tax practice. The book is written primarily as a desk reference for tax practitioners and is organized into four parts. Part I provides an overview of the U.S. system for taxing international transactions, and also discusses the U.S. jurisdictional rules and source-of-income rules. Part II explains how the United States taxes the foreign activities of U.S. persons, and includes chapters on the foreign tax credit, deemed paid foreign tax credit, anti-deferral provisions, foreign currency translation and transactions, export tax benefits, planning for foreign operations, and state taxation of foreign operations. Part III describes how the United States taxes the U.S. activities of foreign persons, including the taxation of U.S.-source investment-type income and U.S. trade or business activities, as well as planning for foreign-owned U.S. operations. Finally, Part IV covers issues common to both outbound and inbound activities, including intercompany transfer pricing, tax treaties, cross-border mergers and acquisitions, and international tax practice and procedure.