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The Transfer Pricing Problem
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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.
Book Synopsis The Transfer Pricing Problem by : James R. Hines
Download or read book The Transfer Pricing Problem written by James R. Hines and published by . This book was released on 1990 with total page 54 pages. Available in PDF, EPUB and Kindle. Book excerpt: Section 1 introduces the material. Section 2 of this paper describes the transfer pricing problem and some solutions that have been proposed in the past. Section 3 offers a different solution and demonstrates that it supports an efficient allocation of resources. Section 4 briefly discusses some of the complications that arise in practice, analyzes methods governments have employed to address this problem, and argues that the solution corresponds to concepts of income division that governments have tried to employ in broader contexts.
Book Synopsis The Transfer Pricing Problem: where the Profits are by : James R. Hines (jr.)
Download or read book The Transfer Pricing Problem: where the Profits are written by James R. Hines (jr.) and published by . This book was released on 1990 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Addressing the Transfer-pricing Problem in an Origin-basis X Tax by : David F. Bradford
Download or read book Addressing the Transfer-pricing Problem in an Origin-basis X Tax written by David F. Bradford and published by . This book was released on 2003 with total page 35 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a previous paper I described how the tax design called the X Tax would facilitate an international tax system free of many of the complexities and avoidance opportunities plaguing the existing international tax regime and also have neutrality properties generally deemed desirable. A choice must, however, be made between two basic treatments of transborder business transactions --the origin and destination principles. The destination-principle approach sidesteps the need to identify arm's length terms of transborder transactions between related business entities -- the transfer-pricing problem. This serious problem remains in the origin-principle approach, which, however, presents fewer challenges of monitoring the flow of goods and services across borders, obviates what I call the tourism problem' whereby people can reduce their taxes by consuming in a low-tax jurisdiction and, arguably most important, avoids transition effects associated with introduction of the tax and subsequent tax rate changes that occur in the destination approach. In this paper I explore possible special rules for transborder transactions between related parties in an origin-based system to eliminate the transfer-pricing problem
Book Synopsis Transfer Pricing and Corporate Taxation by : Elizabeth King
Download or read book Transfer Pricing and Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2008-10-11 with total page 199 pages. Available in PDF, EPUB and Kindle. Book excerpt: National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.
Book Synopsis The Transfer Pricing Problem: where the Profits are by : James R. Hines (jr.)
Download or read book The Transfer Pricing Problem: where the Profits are written by James R. Hines (jr.) and published by . This book was released on 1990 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis A Look at the Transfer Pricing Problem for U.S. Multinational Corporations by : William S. Dittoe
Download or read book A Look at the Transfer Pricing Problem for U.S. Multinational Corporations written by William S. Dittoe and published by . This book was released on 1981 with total page 130 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Transfer Pricing written by Marc M. Levey and published by CCH Incorporated. This book was released on 2010 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer Pricing: Rules, Compliance and Controversy offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Throughout the book, the authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures.
Book Synopsis Readings in Accounting for Management Control by : David Otley and Kenneth Merchant Clive Emmanuel
Download or read book Readings in Accounting for Management Control written by David Otley and Kenneth Merchant Clive Emmanuel and published by Springer. This book was released on 2013-12-19 with total page 689 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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.
Book Synopsis An Analysis of the Transfer Pricing Problem by : Albert Frakes
Download or read book An Analysis of the Transfer Pricing Problem written by Albert Frakes and published by . This book was released on 1964 with total page 61 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Transfer Pricing Problem by : Steva Kosanovic
Download or read book The Transfer Pricing Problem written by Steva Kosanovic and published by . This book was released on 1993 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book International Taxation written by and published by DIANE Publishing. This book was released on 1993 with total page 170 pages. Available in PDF, EPUB and Kindle. Book excerpt: Covers: whether foreign-controlled companies might have underpaid U.S. income taxes by improperly using transfer pricing; what factors, if any, affected the IRS1 ability to determine and recover any potentially underpaid taxes; and what alternatives to dealing with transfer pricing existed. Charts and tables.
Book Synopsis The Transfer Pricing Problem and the Multinational Firm by : Roger Edward Roberts
Download or read book The Transfer Pricing Problem and the Multinational Firm written by Roger Edward Roberts and published by . This book was released on 1967 with total page 164 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs Publisher :Organisation for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Center ISBN 13 : Total Pages :104 pages Book Rating :4.:/5 (41 download)
Book Synopsis Transfer Pricing and Multinational Enterprises by : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs
Download or read book Transfer Pricing and Multinational Enterprises written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by Organisation for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Center. This book was released on 1984-10 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt: Digitised document - Electronic release on 24/11/2011
Book Synopsis Transfer Pricing and Multinational Enterprises by : OECD
Download or read book Transfer Pricing and Multinational Enterprises written by OECD and published by OECD Publishing. This book was released on 1979-06-01 with total page 107 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.
Book Synopsis 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.
