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The Impact Of The Covid 19 Pandemic On Advance Pricing Agreements
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Book Synopsis The Impact of the COVID-19 Pandemic on Advance Pricing Agreements by : B. Gibert
Download or read book The Impact of the COVID-19 Pandemic on Advance Pricing Agreements written by B. Gibert and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The COVID-19 pandemic may impact transfer pricing policies applied within multinational groups. As a result, one could legitimately wonder whether the pandemic could also impact advance pricing agreements (APAs) either concluded or under discussion between tax administrations and enterprises. This question is of foremost importance given that the terms and conditions of APAs are set to ensure tax certainty. In such circumstances, taxpayers could examine how potential changes triggered by the COVID-19 pandemic could impact APAs (section 1.) and what the procedural impact of the COVID-19 pandemic would be on APAs concluded or under discussion (section 2.).
Book Synopsis Advance Pricing Agreements and COVID-19 by : S.F. Foley
Download or read book Advance Pricing Agreements and COVID-19 written by S.F. Foley and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors explain how recent changes to the U.S. advance pricing agreement (APA) model confirm the potential to amend existing APAs and highlight the value of the APA process to address extraordinary economic disruption through tailored long-term solutions.
Book Synopsis Transfer Pricing Developments Around the World 2022 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2022 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2022-10-11 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with a far-reaching impact on countries’ legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the 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), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments. Transfer Pricing Developments in the European Union. Transfer Pricing Developments in the United States. Transfer Pricing Developments in Developing Countries and Emerging Economies. Recent Developments on Transfer Pricing in the Post-Covid-19 Era. Recent Developments on Transfer Pricing and Substance. Recent Developments on Transfer Pricing and Business Restructurings. Recent Developments on Transfer Pricing and New Technologies. The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players, including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating efficient dialog and a coordinated approach to transfer pricing in the future.
Book Synopsis Transfer Pricing and Intra-group Financing by : Anuschka Bakker
Download or read book Transfer Pricing and Intra-group Financing written by Anuschka Bakker and published by IBFD. This book was released on 2012 with total page 593 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
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.
Book Synopsis Evolution of APA Regime by : Kuldeep Sharma
Download or read book Evolution of APA Regime written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-07-19 with total page 252 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.
Book Synopsis Global Trends 2040 by : National Intelligence Council
Download or read book Global Trends 2040 written by National Intelligence Council and published by Cosimo Reports. This book was released on 2021-03 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The ongoing COVID-19 pandemic marks the most significant, singular global disruption since World War II, with health, economic, political, and security implications that will ripple for years to come." -Global Trends 2040 (2021) Global Trends 2040-A More Contested World (2021), released by the US National Intelligence Council, is the latest report in its series of reports starting in 1997 about megatrends and the world's future. This report, strongly influenced by the COVID-19 pandemic, paints a bleak picture of the future and describes a contested, fragmented and turbulent world. It specifically discusses the four main trends that will shape tomorrow's world: - Demographics-by 2040, 1.4 billion people will be added mostly in Africa and South Asia. - Economics-increased government debt and concentrated economic power will escalate problems for the poor and middleclass. - Climate-a hotter world will increase water, food, and health insecurity. - Technology-the emergence of new technologies could both solve and cause problems for human life. Students of trends, policymakers, entrepreneurs, academics, journalists and anyone eager for a glimpse into the next decades, will find this report, with colored graphs, essential reading.
Author :National Academies of Sciences, Engineering, and Medicine Publisher :National Academies Press ISBN 13 :0309676908 Total Pages :81 pages Book Rating :4.3/5 (96 download)
Book Synopsis Rapid Expert Consultations on the COVID-19 Pandemic by : National Academies of Sciences, Engineering, and Medicine
Download or read book Rapid Expert Consultations on the COVID-19 Pandemic written by National Academies of Sciences, Engineering, and Medicine and published by National Academies Press. This book was released on 2020-05-30 with total page 81 pages. Available in PDF, EPUB and Kindle. Book excerpt: In response to a request from the Office of Science and Technology Policy and the Office of the Assistant Secretary for Preparedness and Response, the National Academies of Sciences, Engineering, and Medicine convened a standing committee of experts to help inform the federal government on critical science and policy issues related to emerging infectious diseases and other 21st century health threats. This set of Rapid Expert Consultations are the first of their kind and represent the best evidence available to the Committee at the time each publication was released. The science on these issues is continually evolving, and the scientific consensus the Committee reaches on these topics will likely evolve with it. The standing committee includes members with expertise in emerging infectious diseases, public health, public health preparedness and response, biological sciences, clinical care and crisis standards of care, risk communication, and regulatory issues.
Book Synopsis Transfer Pricing in Manufacturing by : Ioana Ignat
Download or read book Transfer Pricing in Manufacturing written by Ioana Ignat and published by Springer Nature. This book was released on 2022-05-09 with total page 196 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is considered a new and complex concept in terms of guidelines and regulations. In this context, more and more academics and tax professionals are interested in understanding the mechanism of a transfer pricing analysis. The main objective of the book is to help them in this process by presenting in a practical approach (using case studies and schemes) and in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations the way in which are operating the basic transfer pricing elements. Moreover, considering that the manufacturing sector is the chief wealth-producing sector of the global economy, the book illustrates complete transfer pricing analyses applicable for manufacturing transactions (using Orbis database). In the end, the book presents some recent disputes between manufacturing entities and tax authorities in relation to the transfer pricing analysis for manufacturing transactions. Chapter “TAMSAT” is available open access under a Creative Commons Attribution 4.0 International License via link.springer.com.
Book Synopsis The COVID-19 Impact on Corporate Leverage and Financial Fragility by : Sharjil M. Haque
Download or read book The COVID-19 Impact on Corporate Leverage and Financial Fragility written by Sharjil M. Haque and published by International Monetary Fund. This book was released on 2021-11-05 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt: We study the impact of the COVID-19 recession on capital structure of publicly listed U.S. firms. Our estimates suggest leverage (Net Debt/Asset) decreased by 5.3 percentage points from the pre-shock mean of 19.6 percent, while debt maturity increased moderately. This de-leveraging effect is stronger for firms exposed to significant rollover risk, while firms whose businesses were most vulnerable to social distancing did not reduce leverage. We rationalize our evidence through a structural model of firm value that shows lower expected growth rate and higher volatility of cash flows following COVID-19 reduced optimal levels of corporate leverage. Model-implied optimal leverage indicates firms which did not de-lever became over-leveraged. We find default probability deteriorates most in large, over-leveraged firms and those that were stressed pre-COVID. Additional stress tests predict value of these firms will be less than one standard deviation away from default if cash flows decline by 20 percent.
Book Synopsis Pandemic Economics by : Thomas R. Sadler
Download or read book Pandemic Economics written by Thomas R. Sadler and published by Routledge. This book was released on 2021-07-27 with total page 319 pages. Available in PDF, EPUB and Kindle. Book excerpt: Pandemic Economics applies economic theory to the Covid-19 era, exploring the micro and macro dimensions of the pre-pandemic, pandemic, and post-pandemic phases. Using core economic tools such as marginal analysis, cost-benefit analysis, and opportunity cost, this book explores the breadth of economic outcomes from the pandemic. It shows that a tradeoff between public health and economic health led to widespread problems, including virus infections and unemployment. Taking an international and comparative approach, the book shows that because countries implemented different economic policies, interventions, and timelines during the crisis, outcomes varied with respect to the extent of recession, process of recovery, availability of medical equipment, public health, and additional waves of the virus. Pedagogical features are weaved throughout the text, including country case studies, key terms, suggested further reading, and discussion questions for solo or group study. On top of this, the book offers online supplements comprising PowerPoint slides, test questions, extra case studies, and an instructor guide. This textbook will be a valuable resource for advanced undergraduate and postgraduate courses on pandemic economics, macroeconomics, health economics, public policy, and related areas.
Book Synopsis Tax Transfer Pricing by : Andrea Musselli
Download or read book Tax Transfer Pricing written by Andrea Musselli and published by Gruppo 24 Ore. This book was released on 2022-09-15T00:00:00+02:00 with total page 446 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.
Book Synopsis Comparative Law Yearbook of International Business Volume 43 by : Christian Campbell
Download or read book Comparative Law Yearbook of International Business Volume 43 written by Christian Campbell and published by Kluwer Law International B.V.. This book was released on 2021-11-11 with total page 195 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Comparative Law Yearbook of International Business, published under the auspices of the Center for International Legal Studies, in this 43rd volume spans an arc of timely and challenging concerns for business law practitioners and academics alike. It discusses: how arbitrability of intellectual property rights disputes might improve worldwide IPR enforcement; how the “disregard of legal entity” may be used to establish implied consent by a person or entity that is not a signatory to an arbitration agreement; how an effective cross-border insolvency framework under the Indian insolvency and bankruptcy code can borrow from the UNCITRAL Model Law’s and other jurisdictions’ approaches to the tension between “universality” and “territoriality”; how a promising new mediation act for Pakistan may help resolve a backlog of millions of cases in a jurisdiction with a patchwork of traditional and modern alternative dispute resolution mechanisms; how the European Union seeks to balance the taxation of digital services; how Brazil is addressing the taxation of offshore indirect transfers; how private equity capital structures in the unique market of professional sports create opportunities as well as risks; how Securities Market Regulation theory plays a role in the organization and development of active securities markets, particularly in emerging markets; and how non-signatories can be bound by arbitration agreements in Brazil through “disregard of legal entity” to ascertain implied consent. The authors are practitioners and academics from Brazil, England, France, India, Pakistan, Singapore, the United States and Uzbekistan. They offer a broad and diverse perspective on some of today’s pressing business law issues in a shrinking world.
Book Synopsis Consumer Law and Policy by : Iain Ramsay
Download or read book Consumer Law and Policy written by Iain Ramsay and published by Bloomsbury Publishing. This book was released on 2012-10-25 with total page 515 pages. Available in PDF, EPUB and Kindle. Book excerpt: This new edition continues to provide a critical introduction to the legal regulation of consumer markets, situating it within the context of broader debates about rationales for regulation, the role of the state and the growth of neo-liberalism. It draws on interdisciplinary sources, assessing, for example, the increased influence of behavioural economics on consumer law. It analyses the Europeanisation of consumer law and the tensions between neo-liberalism and the social market, consumer protection and consumer choice, in the establishment of the single market ground rules. The book also assesses national, regional and international responses to the world financial crisis as reflected in the regulation of consumer credit markets. This edition incorporates recent legislative and judicial developments of the law, blending substantial extracts from primary UK, EU and international legal materials.
Author :National Academies of Sciences, Engineering, and Medicine Publisher :National Academies Press ISBN 13 :0309680077 Total Pages :115 pages Book Rating :4.3/5 (96 download)
Book Synopsis Reopening K-12 Schools During the COVID-19 Pandemic by : National Academies of Sciences, Engineering, and Medicine
Download or read book Reopening K-12 Schools During the COVID-19 Pandemic written by National Academies of Sciences, Engineering, and Medicine and published by National Academies Press. This book was released on 2020-11-08 with total page 115 pages. Available in PDF, EPUB and Kindle. Book excerpt: The COVID-19 pandemic has presented unprecedented challenges to the nation's K-12 education system. The rush to slow the spread of the virus led to closures of schools across the country, with little time to ensure continuity of instruction or to create a framework for deciding when and how to reopen schools. States, districts, and schools are now grappling with the complex and high-stakes questions of whether to reopen school buildings and how to operate them safely if they do reopen. These decisions need to be informed by the most up-to-date evidence about the SARS-CoV-2 virus that causes COVID-19; about the impacts of school closures on students and families; and about the complexities of operating school buildings as the pandemic persists. Reopening K-12 Schools During the COVID-19 Pandemic: Prioritizing Health, Equity, and Communities provides guidance on the reopening and operation of elementary and secondary schools for the 2020-2021 school year. The recommendations of this report are designed to help districts and schools successfully navigate the complex decisions around reopening school buildings, keeping them open, and operating them safely.
Book Synopsis Just Another Crisis? The Impact of the COVID-19 Pandemic on Southeast Asia’s Rice Sector by : Jamie Seth Davidson
Download or read book Just Another Crisis? The Impact of the COVID-19 Pandemic on Southeast Asia’s Rice Sector written by Jamie Seth Davidson and published by ISEAS-Yusof Ishak Institute. This book was released on 2023-05-11 with total page 215 pages. Available in PDF, EPUB and Kindle. Book excerpt: “This timely volume chronicles and analyses the intersection of rice policies and the pandemic through case studies of a diverse range of Southeast Asian countries: rice exporters, rice importers and city-states. There is no group of eminent researchers better suited to carrying out this work, and they conduct the analysis by illuminating the historical context that is essential to an understanding of rice policies in the region. This volume is a must-read for anyone interested in rice policies and politics in contemporary Southeast Asia.”--David Dawe, Former Senior Economist with the International Rice Research Institute and the Food and Agricultural Organization. “This is highly recommended reading for those interested in an up-to-date and in-depth treatment of the political economy of rice policies in five major ASEAN countries, one chapter per country. While the book title indicates a topical focus on the impact of the COVID-19 pandemic on Southeast Asia’s rice sector, these chapters are much more than this, giving considerable historical context leading up to the outbreak of the pandemic and looking forward after the pandemic.”--Howarth Bouis, Laureate, World Food Prize; Emeritus Fellow, International Food Policy Research Institute
Book Synopsis Powering the Digital Economy: Opportunities and Risks of Artificial Intelligence in Finance by : El Bachir Boukherouaa
Download or read book Powering the Digital Economy: Opportunities and Risks of Artificial Intelligence in Finance written by El Bachir Boukherouaa and published by International Monetary Fund. This book was released on 2021-10-22 with total page 35 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper discusses the impact of the rapid adoption of artificial intelligence (AI) and machine learning (ML) in the financial sector. It highlights the benefits these technologies bring in terms of financial deepening and efficiency, while raising concerns about its potential in widening the digital divide between advanced and developing economies. The paper advances the discussion on the impact of this technology by distilling and categorizing the unique risks that it could pose to the integrity and stability of the financial system, policy challenges, and potential regulatory approaches. The evolving nature of this technology and its application in finance means that the full extent of its strengths and weaknesses is yet to be fully understood. Given the risk of unexpected pitfalls, countries will need to strengthen prudential oversight.
