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Author : Roger Edward Roberts
Publisher :
ISBN 13 :
Total Pages : 164 pages
Book Rating : 4.:/5 (613 download)
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 : OECD
Publisher : OECD Publishing
ISBN 13 : 9264167773
Total Pages : 107 pages
Book Rating : 4.2/5 (641 download)
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.
Author : James S. Shulman
Publisher : Forgotten Books
ISBN 13 : 9781528449021
Total Pages : 46 pages
Book Rating : 4.4/5 (49 download)
Download or read book Transfer Pricing in the Multinational Firm (Classic Reprint) written by James S. Shulman and published by Forgotten Books. This book was released on 2017-09-12 with total page 46 pages. Available in PDF, EPUB and Kindle. Book excerpt: Excerpt from Transfer Pricing in the Multinational Firm The spread of decentralized corporate operations has been accompanied by widespread utilization Of the profit center concept to measure, evaluate, and motivate divisional management. As the implications of the profit center idea have been recognized, the need has arisen for rational systems to price intra-company transfers of goods at varying stages of production. The aim, in general, has been to devise methods which would satisfy' the goals of divisional managers to earn adequate profit for their divisions, while simultaneously furthering corporate profit goals. In single country Operations, the system is meant to function for this purpose and to provide a foundation for a properly Operating control system. But when a company operates across national borders and exports its practice of decentralized management, with all the accompanying apparatus, new complicating dimensions are added. In international business, there are Opportunities to maximize profits which may override the significance of a control system and the transfer pricing mechanism. Likewise, this environment contains threats to international firms, often unforeseen and, even when perceived, seldom factored into control systems. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.
Author : Alan M. Rugman
Publisher : Routledge
ISBN 13 : 1351999680
Total Pages : 292 pages
Book Rating : 4.3/5 (519 download)
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.
Author : JAMES S. SHULMAN
Publisher :
ISBN 13 : 9781033022245
Total Pages : 0 pages
Book Rating : 4.0/5 (222 download)
Download or read book TRANSFER PRICING IN THE MULTINATIONAL FIRM written by JAMES S. SHULMAN and published by . This book was released on 2018 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Elizabeth King
Publisher : Springer Science & Business Media
ISBN 13 : 0387781838
Total Pages : 199 pages
Book Rating : 4.3/5 (877 download)
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.
Author : Lorraine Eden
Publisher : University of Toronto Press
ISBN 13 : 9780802007766
Total Pages : 788 pages
Book Rating : 4.0/5 (77 download)
Download or read book Taxing Multinationals written by Lorraine Eden and published by University of Toronto Press. This book was released on 1998-01-01 with total page 788 pages. Available in PDF, EPUB and Kindle. Book excerpt: Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264167803
Total Pages : 90 pages
Book Rating : 4.2/5 (641 download)
Download or read book Transfer Pricing and Multinational Enterprises Three Taxation Issues written by OECD and published by OECD Publishing. This book was released on 1984-10-01 with total page 90 pages. Available in PDF, EPUB and Kindle. Book excerpt: Digitised document - Electronic release on 24/11/2011
Author : Jerome Monsenego
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403514930
Total Pages : 281 pages
Book Rating : 4.4/5 (35 download)
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.
Author : Wagdy M. Abdallah
Publisher : Praeger
ISBN 13 :
Total Pages : 184 pages
Book Rating : 4.:/5 (318 download)
Download or read book International Transfer Pricing Policies written by Wagdy M. Abdallah and published by Praeger. This book was released on 1989-03-13 with total page 184 pages. Available in PDF, EPUB and Kindle. Book excerpt: "In this valuable work Professor Abdallah lays out the factors a good international transfer pricing system should have. . . . A multinational enterprise must reach a number of business decisions involving transfer pricing, such as where to manufacture a specific product, levels of capital investment, and profit planning by location. Rather than shooting from the hip' and trying to solve problems one at a time, Professor Abdallah says, companies should develop a comprehensive policy to resolve the inevitable problems. In short, transfer pricing problems are here and will continue to be here. While there is no single answer, a written policy approach is best. Anyone responsible for international transfer pricing will be helped immeasurably by referring to this valuable book." Management Accounting
Author : James S. Shulman
Publisher :
ISBN 13 :
Total Pages : 42 pages
Book Rating : 4.:/5 (143 download)
Download or read book Transfer Pricing in the Multinational Firm written by James S. Shulman and published by . This book was released on 1968 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : William S. Dittoe
Publisher :
ISBN 13 :
Total Pages : 130 pages
Book Rating : 4.:/5 (843 download)
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:
Author : Wolfgang Schön
Publisher : Springer Science & Business Media
ISBN 13 : 3642259804
Total Pages : 308 pages
Book Rating : 4.6/5 (422 download)
Download or read book Fundamentals of International Transfer Pricing in Law and Economics written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2012-02-15 with total page 308 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.
Author : Erik Wintzer
Publisher : GRIN Verlag
ISBN 13 : 3638698106
Total Pages : 61 pages
Book Rating : 4.6/5 (386 download)
Download or read book Transfer Pricing for Multinational Enterprises. An Integrated Approach written by Erik Wintzer and published by GRIN Verlag. This book was released on 2007-08 with total page 61 pages. Available in PDF, EPUB and Kindle. Book excerpt: Diploma Thesis from the year 2003 in the subject Business economics - Accounting and Taxes, grade: 2,0 (B), Schmalkalden University of Applied Sciences (Economics), course: Cost Pricing und Controlling, 121 entries in the bibliography, language: English, abstract: Globalization of business has replaced the concept of national exchanges with global transactions. Consequently, the changes due to globalization play a big role in the strategy of multinational enterprises. The volume of intrafirm trade is huge and expanding rapidly as multinationals globalize their investment and trade. Today, a considerable proportion of world trade takes place within multinational enterprises. This indicates the importance of transfer pricing conspicuously. The intention of this book is to describe the challenge of transfer pricing holistically and to exhibit some options for multinational enterprises determining their transfer prices. While management accounting as well as strategic aspects of transfer prices are also relevant for enterprises, which are not multinational, external aspects (specifically tax accounting) are typically only crucial for multinationals. This book is an attempt to integrate all aspects of transfer pricing targeting practitioners as well as economists.
Author : Suleiman Khalil Kassicieh
Publisher :
ISBN 13 :
Total Pages : 196 pages
Book Rating : 4.:/5 (173 download)
Download or read book The Multinational Corporation and the Transfer Pricing Problem written by Suleiman Khalil Kassicieh and published by . This book was released on 1978 with total page 196 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Alan M. Rugman
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (71 download)
Download or read book Transfer Pricing Problems and the Multinational Corporations written by Alan M. Rugman and published by . This book was released on 1979 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Markus Brem
Publisher :
ISBN 13 :
Total Pages : 20 pages
Book Rating : 4.:/5 (129 download)
Download or read book On Transfer Pricing Conceptual Thoughts on the Nature of the Multinational Firm written by Markus Brem and published by . This book was released on 2013 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper deploys Transaction Cost Economics (TCE) to elaborate on the shortcomings of mainstream transfer pricing in multinational firms. Departing from the notion that multinationals increasingly (re-)organize their business along multinational value chains irrespective of jurisdictional borders, the paper discusses the nature of the multinational firm and the problem of choosing the right intra-group (transfer) price. The mainstream transfer pricing approach derived from the Arm's Length Principle is deemed inappropriate for globalized MNEs. Referring to the value chain model, the paper suggests that entrepreneurial coordination is the key performance feature to be used for valuing business activity and for allocating - for tax transfer pricing purposes - standard markups and residual profits along the value chain.
