OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

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Publisher : OECD Publishing
ISBN 13 : 9264265120
Total Pages : 612 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 612 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.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

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Publisher : OECD Publishing
ISBN 13 : 9264921915
Total Pages : 658 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 658 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.

Dealing Effectively with the Challenges of Transfer Pricing

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264169466
Total Pages : 110 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Dealing Effectively with the Challenges of Transfer Pricing by : OECD

Download or read book Dealing Effectively with the Challenges of Transfer Pricing written by OECD and published by OECD Publishing. This book was released on 2012-01-18 with total page 110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report addresses the practical administration of transfer pricing programmes by tax administrations.

Transfer Pricing in China

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Author :
Publisher : Springer Science & Business Media
ISBN 13 : 3642160808
Total Pages : 93 pages
Book Rating : 4.6/5 (421 download)

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Book Synopsis Transfer Pricing in China by : Chris Devonshire-Ellis

Download or read book Transfer Pricing in China written by Chris Devonshire-Ellis and published by Springer Science & Business Media. This book was released on 2011-05-18 with total page 93 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Guide is a detailed overview of all aspects of transfer pricing in China. Produced in association with Transfer Pricing Associates, a specialist global transfer pricing firm, this is an essential work for any businessman trading with or conducting business in China. The book deals with all aspects of transfer pricing from a practical perspective, from designing and implementing a transfer pricing system, to managing China compliance and preparing for an audit.

The DEMPE Concept and Intangibles

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403540508
Total Pages : 243 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis The DEMPE Concept and Intangibles by : Karol Dziwinski

Download or read book The DEMPE Concept and Intangibles written by Karol Dziwinski and published by Kluwer Law International B.V.. This book was released on 2022-06-06 with total page 243 pages. Available in PDF, EPUB and Kindle. Book excerpt: Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle – known as DEMPE (development, enhancement, maintenance, protection and exploitation) – describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following: role of the DEMPE concept within the framework of international tax law and transfer pricing; interplay of the DEMPE concept with the arm’s length principle; full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences; modes of application of the DEMPE concept which can be directly implemented in practice; and additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept. The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations. Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises – and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept – tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.

Transfer Pricing in China

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Author :
Publisher : Springer
ISBN 13 : 9811376891
Total Pages : 192 pages
Book Rating : 4.8/5 (113 download)

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Book Synopsis Transfer Pricing in China by : Jian Li

Download or read book Transfer Pricing in China written by Jian Li and published by Springer. This book was released on 2019-05-30 with total page 192 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book offers up to date insights into the exciting world of China’s extensive economic activity through the pervasive and often secretive practice of transfer pricing. It begins with an explanation of transfer pricing itself and goes on to explore how intricately it can infiltrate the trading practices of the commercial lives of both foreign companies in China and Chinese companies expanding to other countries. A review of the main industries in China also considers their possible future uncertainties. China has joined other authorities in actively legislating and organizing a regime to implement its arm’s length policy, as related in Part I of the book on concepts and controls. This is then followed by Part 2 which is devoted to a collection of cases showing the breadth and variability of companies actively seeking to maximise their profits, while Part 3 of the book gives a rare record of the order of priorities exercised by one hundred Chinese tax officers engaged in auditing company performance. The book ends with a summary of the future trends, and activities that regulatory authorities are likely to undertake.

Tax Administration Reform in China

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Publisher : International Monetary Fund
ISBN 13 : 1475523610
Total Pages : 67 pages
Book Rating : 4.4/5 (755 download)

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Book Synopsis Tax Administration Reform in China by : John Brondolo

Download or read book Tax Administration Reform in China written by John Brondolo and published by International Monetary Fund. This book was released on 2016-03-17 with total page 67 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax administration improvements have contributed significantly to a doubling of China’s tax-to-GDP ratio and the substantial reduction in taxpayers’ compliance costs since the mid-1990s. This paper describes the key features of China’s tax administration and their evolution over the last 20 years. It also identifes emerging challenges to the tax system and areas where further tax administration improvements are needed to sustain tax revenue and reduce taxpayers’ compliance costs in the future.

Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

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Author :
Publisher : Organisation for Economic Co-operation and Development
ISBN 13 :
Total Pages : 76 pages
Book Rating : 4.:/5 (318 download)

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Book Synopsis Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations by : Organisation for Economic Co-operation and Development

Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development. This book was released on 1995 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt: Includes 1999 update. 1998 update in back.

United Nations Practical Manual on Transfer Pricing for Developing Countries 2017

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Publisher :
ISBN 13 :
Total Pages : 672 pages
Book Rating : 4.:/5 (31 download)

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Book Synopsis United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 by : United Nations

Download or read book United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 written by United Nations and published by . This book was released on 2017 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.

Transfer Pricing and Dispute Resolution

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Author :
Publisher : IBFD
ISBN 13 : 9087221002
Total Pages : 807 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Transfer Pricing and Dispute Resolution by : Anuschka Bakker

Download or read book Transfer Pricing and Dispute Resolution written by Anuschka Bakker and published by IBFD. This book was released on 2011 with total page 807 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.

GAARs - a Key Element of Tax Systems in the Post-BEPS Tax World

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Publisher :
ISBN 13 : 9789087223588
Total Pages : 840 pages
Book Rating : 4.2/5 (235 download)

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Book Synopsis GAARs - a Key Element of Tax Systems in the Post-BEPS Tax World by : Michael Lang

Download or read book GAARs - a Key Element of Tax Systems in the Post-BEPS Tax World written by Michael Lang and published by . This book was released on 2016 with total page 840 pages. Available in PDF, EPUB and Kindle. Book excerpt: General anti-avoidance rules (GAARs) have been a topic of great relevance in practice as well as in academia for decades. In a post-BEPS tax world, with national legislators introducing or tightening GAARs, and with the European Union and OECD suggesting implementation of such rules, the topic seems more important than ever. The aim of this book is to give tax policymakers, tax authorities, tax courts and tax practitioners an idea of the various understandings of and approaches towards tax avoidance in 39 countries.

Securing the Belt and Road Initiative

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Publisher : Springer
ISBN 13 : 9811071160
Total Pages : 311 pages
Book Rating : 4.8/5 (11 download)

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Book Synopsis Securing the Belt and Road Initiative by : Alessandro Arduino

Download or read book Securing the Belt and Road Initiative written by Alessandro Arduino and published by Springer. This book was released on 2018-02-01 with total page 311 pages. Available in PDF, EPUB and Kindle. Book excerpt: This collection explores the expansion of Chinese outbound investments, aimed to sustain the increased need for natural resources, and how they have amplified the magnitude of a possible international crisis that the People’s Republic of China may face in the near future by bringing together the views of a wide range of scholars. President Xi’s Belt and Road initiative (BRI), aimed to promote economic development and exchanges with China for over 60 countries, necessitates a wide range of security procedures. While the threats to Chinese enterprises and Chinese workers based on foreign soil are poised to increase, there is an urgent need to develop new guidelines for risk assessment, special insurance and crisis management. While the Chinese State Owned Enterprises are expanding their international reach capabilities, they still do not have the capacity to assure adequate security. In such a climate, this collection will be of profound value to policy makers, those working in the financial sector, and academics.

Resolving Transfer Pricing Disputes

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Publisher : Cambridge University Press
ISBN 13 : 1139916289
Total Pages : 975 pages
Book Rating : 4.1/5 (399 download)

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Book Synopsis Resolving Transfer Pricing Disputes by : Eduardo Baistrocchi

Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

Resolving China’s Corporate Debt Problem

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Publisher : International Monetary Fund
ISBN 13 : 1475545282
Total Pages : 43 pages
Book Rating : 4.4/5 (755 download)

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Book Synopsis Resolving China’s Corporate Debt Problem by : Wojciech Maliszewski

Download or read book Resolving China’s Corporate Debt Problem written by Wojciech Maliszewski and published by International Monetary Fund. This book was released on 2016-10-14 with total page 43 pages. Available in PDF, EPUB and Kindle. Book excerpt: Corporate credit growth in China has been excessive in recent years. This credit boom is related to the large increase in investment after the Global Financial Crisis. Investment efficiency has fallen and the financial performance of corporates has deteriorated steadily, affecting asset quality in financial institutions. The corporate debt problem should be addressed urgently with a comprehensive strategy. Key elements should include identifying companies in financial difficulties, proactively recognizing losses in the financial system, burden sharing, corporate restructuring and governance reform, hardening budget constraints, and facilitating market entry. A proactive strategy would trade off short-term economic pain for larger longer-term gain.

Addressing Base Erosion and Profit Shifting

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264192743
Total Pages : 91 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Addressing Base Erosion and Profit Shifting by : OECD

Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

Ask a Manager

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Publisher : Ballantine Books
ISBN 13 : 0399181822
Total Pages : 306 pages
Book Rating : 4.3/5 (991 download)

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Book Synopsis Ask a Manager by : Alison Green

Download or read book Ask a Manager written by Alison Green and published by Ballantine Books. This book was released on 2018-05-01 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: From the creator of the popular website Ask a Manager and New York’s work-advice columnist comes a witty, practical guide to 200 difficult professional conversations—featuring all-new advice! There’s a reason Alison Green has been called “the Dear Abby of the work world.” Ten years as a workplace-advice columnist have taught her that people avoid awkward conversations in the office because they simply don’t know what to say. Thankfully, Green does—and in this incredibly helpful book, she tackles the tough discussions you may need to have during your career. You’ll learn what to say when • coworkers push their work on you—then take credit for it • you accidentally trash-talk someone in an email then hit “reply all” • you’re being micromanaged—or not being managed at all • you catch a colleague in a lie • your boss seems unhappy with your work • your cubemate’s loud speakerphone is making you homicidal • you got drunk at the holiday party Praise for Ask a Manager “A must-read for anyone who works . . . [Alison Green’s] advice boils down to the idea that you should be professional (even when others are not) and that communicating in a straightforward manner with candor and kindness will get you far, no matter where you work.”—Booklist (starred review) “The author’s friendly, warm, no-nonsense writing is a pleasure to read, and her advice can be widely applied to relationships in all areas of readers’ lives. Ideal for anyone new to the job market or new to management, or anyone hoping to improve their work experience.”—Library Journal (starred review) “I am a huge fan of Alison Green’s Ask a Manager column. This book is even better. It teaches us how to deal with many of the most vexing big and little problems in our workplaces—and to do so with grace, confidence, and a sense of humor.”—Robert Sutton, Stanford professor and author of The No Asshole Rule and The Asshole Survival Guide “Ask a Manager is the ultimate playbook for navigating the traditional workforce in a diplomatic but firm way.”—Erin Lowry, author of Broke Millennial: Stop Scraping By and Get Your Financial Life Together

Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report

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Author :
Publisher : OCDE
ISBN 13 : 9789264241466
Total Pages : 70 pages
Book Rating : 4.2/5 (414 download)

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Book Synopsis Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report by : OCDE,

Download or read book Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report written by OCDE, and published by OCDE. This book was released on 2015 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports