International Transfer Pricing in Theory and Practice

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Publisher :
ISBN 13 : 9788759384541
Total Pages : 206 pages
Book Rating : 4.3/5 (845 download)

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Book Synopsis International Transfer Pricing in Theory and Practice by : Christian Plesner Rossing

Download or read book International Transfer Pricing in Theory and Practice written by Christian Plesner Rossing and published by . This book was released on 2011 with total page 206 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Transfer Pricing Manual

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Publisher :
ISBN 13 : 9780906524145
Total Pages : 446 pages
Book Rating : 4.5/5 (241 download)

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Book Synopsis Transfer Pricing Manual by : Gareth Green

Download or read book Transfer Pricing Manual written by Gareth Green and published by . This book was released on 2008-01-01 with total page 446 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Transfer Pricing Methods

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Author :
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

Introduction to Transfer Pricing

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Author :
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.

Global Transfer Pricing

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Publisher : Tottel Publishing
ISBN 13 : 9781847663962
Total Pages : 0 pages
Book Rating : 4.6/5 (639 download)

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Book Synopsis Global Transfer Pricing by : Chris Adams

Download or read book Global Transfer Pricing written by Chris Adams and published by Tottel Publishing. This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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

Global Transfer Pricing: Principles and Practice 4th Edition (Nordic Edition)

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Publisher : Bloomsbury Professional
ISBN 13 : 9781526514097
Total Pages : 328 pages
Book Rating : 4.5/5 (14 download)

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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. --

Introduction to Transfer Pricing, Second Edition

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Publisher :
ISBN 13 : 9789403514833
Total Pages : 0 pages
Book Rating : 4.5/5 (148 download)

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Book Synopsis Introduction to Transfer Pricing, Second Edition by : Jerome Monsenego

Download or read book Introduction to Transfer Pricing, Second Edition written by Jerome Monsenego and published by . This book was released on 2022-11-22 with total page 0 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.

International Transfer Pricing: The Valuation Of Intangible Assets

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Publisher :
ISBN 13 : 9788189960452
Total Pages : 288 pages
Book Rating : 4.9/5 (64 download)

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Book Synopsis International Transfer Pricing: The Valuation Of Intangible Assets by : Monica Boos

Download or read book International Transfer Pricing: The Valuation Of Intangible Assets written by Monica Boos and published by . This book was released on 2007-01-01 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: The valuation of intangible assets causes tax lawyers and economists a lot of trouble. And when assets cross borders, it gets worse. The (maybe not so-surprising) result is that a considerable number of multinational enterprises use a transfer pricing method to value intangible assets that seems not to comply with regulations of either home or host tax authorities. Although this is a matter of the utmost practical concern, the persistence even growth of the problem clearly raises theoretical issues. This volume considers the valuation of intangible assets from both perspectives, theory and practice, building its practical recommendations on a sound theoretical analysis of the appropriateness of transfer pricing rules for intangible assets as well as on the adequacy of transfer pricing standards and methods for the economic reality of multinational enterprises.

Transfer Pricing

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Publisher : Int. Management Forum (IMF)
ISBN 13 :
Total Pages : 25 pages
Book Rating : 4./5 ( download)

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Book Synopsis Transfer Pricing by : Int. Management Forum (IMF)

Download or read book Transfer Pricing written by Int. Management Forum (IMF) and published by Int. Management Forum (IMF). This book was released on with total page 25 pages. Available in PDF, EPUB and Kindle. Book excerpt: How to deal with international Transfer Pricing risk? Transfer Pricing has drawn the attention of tax authorities worldwide. New rules, documentation requirements and different interpretation given to the OECD Transfer Pricing guidelines by both tax authorities and multinationals have created ground for many disputes. Major Transfer Pricing issues and concerns International Management Forum (IMF) is happy to announce a new distance learning course on Transfer Pricing. This Transfer Pricing course will focus on major Transfer Pricing issues and concerns that all professionals involved in the complex area of Transfer Pricing will face such as: Business Restructuring and Valuation, Transfer Pricing Legislation and Guidelines, Documentation Requirements per region and per country, Transfer Pricing Project and Risk management, Transfer Pricing (pre-) Controversy Management, Design and Development of a Transfer Pricing Policy, types of Intercompany Transactions, Intellectual Property and Customs. Target group of this Transfer Pricing course This new toplevel distance learning Transfer Pricing course has been designed to provide in depth training for financial, tax and Transfer Pricing professionals who are interested in expanding their knowledge of the theory and practice of Transfer Pricing. The course is relevant for Transfer Pricing managers, (inter)national tax managers and firms, finance directors, treasurers, senior executives with an interest in the latest developments in Transfer Pricing and lawyers and accountants who serve their clients with Transfer Pricing issues and have to guide them in the ever-changing Transfer Pricing environment. Note! Salary surveys among accountants, lawyers and economists reveil that practitioners with advanced Transfer Pricing knowlegde often earn more than twice as much as their counterparts with equivalent education and experience who lack Transfer Pricing expertise. Course materials The course consists of 11 lessons, each of which will require about 4 hours of self-study. Next to the lessons, you will also receive 'The Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations' by OECD. All course participants receive a Certificate of Participation.

The Transfer Pricing Problem

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Author :
Publisher : Free Press
ISBN 13 :
Total Pages : 376 pages
Book Rating : 4.:/5 (318 download)

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Book Synopsis The Transfer Pricing Problem by : Robert G. Eccles

Download or read book The Transfer Pricing Problem written by Robert G. Eccles and published by Free Press. This book was released on 1985 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt: Author explores the transfer pricing policies. On the beginning, he identifies the elements of administrative process that are crucial for managing the transfer pricing in corporate practice. Furthermore, he examines the management challenges of the most common transfer pricing policies. Finally, he presents general framework for strategy implementation that is designed to help managers to analyse their own company transfer pricing practices.

Transfer Pricing in Action

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Publisher : Kluwer Law International
ISBN 13 : 9789041146854
Total Pages : 0 pages
Book Rating : 4.1/5 (468 download)

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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.

Multinationals and Transfer Pricing

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Publisher : Routledge
ISBN 13 : 1351999680
Total Pages : 292 pages
Book Rating : 4.3/5 (519 download)

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Book Synopsis Multinationals and Transfer Pricing by : Alan M. Rugman

Download or read book Multinationals and Transfer Pricing written by Alan M. Rugman and published by Routledge. This book was released on 2017-02-03 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: One of the reasons for the success of multinational enterprises in their ability to create in their supranational organisations "internal markets" which eliminate the imperfections of external world markets caused by tariffs on trade, restrictions on the flow of capital, information costs and so on. The method multinationals use to create and sustain internal markets is transfer pricing. Multinationals use to their advantage the difference between nominal accounting and real transfers from their head offices to a subsidiary in different countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals’ use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.

Fundamentals of Transfer Pricing

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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.

Transfer Pricing

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Publisher :
ISBN 13 :
Total Pages : 130 pages
Book Rating : 4.:/5 (16 download)

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Book Synopsis Transfer Pricing by : Raj Preet K. Gill

Download or read book Transfer Pricing written by Raj Preet K. Gill and published by . This book was released on 1984 with total page 130 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Introduction to Transfer Pricing

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Author :
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.

Fundamentals of International Transfer Pricing in Law and Economics

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Author :
Publisher : Springer
ISBN 13 : 9783642434280
Total Pages : 0 pages
Book Rating : 4.4/5 (342 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. This book was released on 2014-04-13 with total page 0 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.

An Investigation Into the Divergence of Theory and Practice Regarding Transfer Pricing Methods

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Author :
Publisher :
ISBN 13 :
Total Pages : 169 pages
Book Rating : 4.:/5 (153 download)

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Book Synopsis An Investigation Into the Divergence of Theory and Practice Regarding Transfer Pricing Methods by : Susan Carol Borkowski

Download or read book An Investigation Into the Divergence of Theory and Practice Regarding Transfer Pricing Methods written by Susan Carol Borkowski and published by . This book was released on 1988 with total page 169 pages. Available in PDF, EPUB and Kindle. Book excerpt: