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Author : Howard Adam Shelanski
Publisher :
ISBN 13 :
Total Pages : 420 pages
Book Rating : 4.:/5 (33 download)
Download or read book Transfer Pricing and the Organization of Intrafirm Exchange written by Howard Adam Shelanski and published by . This book was released on 1993 with total page 420 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Jerome Monsenego
Publisher :
ISBN 13 : 9789144092706
Total Pages : 163 pages
Book Rating : 4.0/5 (927 download)
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.
Author : Lorraine Eden
Publisher :
ISBN 13 : 9781840648324
Total Pages : 0 pages
Book Rating : 4.6/5 (483 download)
Download or read book The Economics of Transfer Pricing written by Lorraine Eden and published by . This book was released on 2019 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This authoritative single-volume collection offers the most influential papers relating to the economics of transfer pricing. The literature notably covers the topic in light of divisionalization, government regulations, bargaining models, market distortions and product characteristics as well as touching on the important subjects of empirical estimates of transfer price manipulation and transfer mispricing estimates. Accompanied by an original introduction by Lorraine Eden, one of the founders and a leading contributor to the field, this volume promises to be useful reading for doctoral students, faculty members and policy makers who wish to extend their knowledge on the economics of transfer pricing.
Author : Robert Feinschreiber
Publisher : John Wiley & Sons
ISBN 13 : 0471651230
Total Pages : 338 pages
Book Rating : 4.4/5 (716 download)
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
Author : David Otley and Kenneth Merchant Clive Emmanuel
Publisher : Springer
ISBN 13 : 1489971386
Total Pages : 689 pages
Book Rating : 4.4/5 (899 download)
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:
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 : Business International Corporation
Publisher :
ISBN 13 :
Total Pages : 212 pages
Book Rating : 4.:/5 (318 download)
Download or read book International Transfer Pricing written by Business International Corporation and published by . This book was released on 1991 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: A comprehensive guide to corporate practices in internal control and tax compliance. Included are case studies of how firms in a variety of industries approach transfer pricing.
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 : Murray Rothbard
Publisher : Ludwig von Mises Institute
ISBN 13 : 1610161688
Total Pages : 358 pages
Book Rating : 4.6/5 (11 download)
Download or read book Review of Austrian Economics, Volume 9 written by Murray Rothbard and published by Ludwig von Mises Institute. This book was released on 2009 with total page 358 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Peter G. Klein
Publisher : Ludwig von Mises Institute
ISBN 13 : 1610165225
Total Pages : 261 pages
Book Rating : 4.6/5 (11 download)
Download or read book The Capitalist & The Entrepreneur written by Peter G. Klein and published by Ludwig von Mises Institute. This book was released on 2010 with total page 261 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Roger Y. Tang
Publisher : Praeger
ISBN 13 :
Total Pages : 208 pages
Book Rating : 4.E/5 ( download)
Download or read book Current Trends and Corporate Cases in Transfer Pricing written by Roger Y. Tang and published by Praeger. This book was released on 2002-04-30 with total page 208 pages. Available in PDF, EPUB and Kindle. Book excerpt: Global changes in business and tax environments are having profound impact on the volume and direction of intrafirm trade and transfer pricing strategies. Tang reports on the findings of a survey of 95 Fortune 1000 companies, sponsored by the Institute of Management Accountants, and provides highly relevant information not easily found on how companies are reacting to this new business environment. He covers corporate financial goals and strategies and divisonal performance measurements systems, among other topics, and gives highly detailed case studies based on reports from five major respondents to his survey: Whirlpool, Dow Chemical, Guidant Corporation, Masco, and Eaton. Tang's book is essential, up-to-date reading for upper level students, researchers, analysts, and corporate executives in multinational firms worldwide. Tang starts with a presentation of the major changes in the global business environment and explains their impact on intrafirm trade and transfer pricing. In Chapter 2 he reports results of his questionnaire survey, and in Chapters 3 to 7 examines up close the details revealed in his five corporate case studies. He compares these corporations in Chapter 8, focusing on corporate strategies and financial goals, transfer pricing and performance evaluation practices, and concommitant tax planning strategies. He then relates his case study research to other major findings derived from his questionnaire survey, and ends the book with a general, summarizing, analytical conclusion.
Author : Raffaele Petruzzi
Publisher : Linde Verlag GmbH
ISBN 13 : 370941038X
Total Pages : 445 pages
Book Rating : 4.7/5 (94 download)
Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi and published by Linde Verlag GmbH. This book was released on 2019-09-02 with total page 445 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264192743
Total Pages : 91 pages
Book Rating : 4.2/5 (641 download)
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.
Author : Centre on Transnational Corporations (United Nations)
Publisher : New York : United Nations
ISBN 13 :
Total Pages : 124 pages
Book Rating : 4.3/5 (91 download)
Download or read book International Income Taxation and Developing Countries written by Centre on Transnational Corporations (United Nations) and published by New York : United Nations. This book was released on 1988 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study on the income tax structure applicable to multinational companies operating in developing countries with reference to double taxation treaties and transfer pricing problems.
Author : Tim Baldenius
Publisher : Now Publishers Inc
ISBN 13 : 1601982704
Total Pages : 107 pages
Book Rating : 4.6/5 (19 download)
Download or read book Internal Pricing written by Tim Baldenius and published by Now Publishers Inc. This book was released on 2009 with total page 107 pages. Available in PDF, EPUB and Kindle. Book excerpt: Internal Pricing surveys of the transfer pricing literature with a focus on commonly-used pricing schemes using incomplete contracting models. Chapter 2 develops the basic symmetric information model to compare the performance of cost-based and negotiated pricing in the absence of external input markets. Chapter 3 considers market-based pricing and the role of internal price adjustments; it ignores investments and focuses solely on trading incentives. Chapter 4 adds investments to the model of Chapter 3 and shows that investment opportunities further strengthen the case for internal adjustments. Chapter 5 reconsiders the initial analysis of Chapter 2 for the case of asymmetrically informed divisional managers. The book ends with the author's conclusions and an appendix including the mathematical proofs. A key theme running through Internal Pricing is that the firm's central office (i.e headquarters) plays a rather limited role in mediating individual transactions. This captures the stylized empirical fact that in most firms, headquarters designs the broad "rules of the game" by choosing a pricing mechanism and compensation contracts, but usually does not get involved in pricing on a product-by-product basis.
Author : Lorraine Eden
Publisher : CreateSpace
ISBN 13 : 9781491211342
Total Pages : 64 pages
Book Rating : 4.2/5 (113 download)
Download or read book Transfer Pricing, Intrafirm Trade and the BLS International Price Program written by Lorraine Eden and published by CreateSpace. This book was released on 2013-07-31 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: Most governments keep balance of payments statistics on exports and imports, by value, andconstruct international prices indexes in order to deflate these statistics. How can intrafirm trade(IFT), trade between related parties such as multinational enterprises (MNEs), bias theconstruction of these international price indexes? Economists have known for many years thatthe prices set by MNEs for intrafirm transfers -- transfer prices --- are normally not the prices that would be negotiated between arm's length parties (Diewert 1985, Eden 1985, Horst 1971).Does transfer pricing bias the export and import price indexes in any predictable fashion? Iffirms manipulate transfer prices to avoid taxes or tariffs, what is the appropriate transfer price touse in constructing export and import price indexes, in theory and in practice? These issues are important because related party trade is huge, representing half of US imports and one-third of US exports, and perhaps a third of worldwide merchandise trade flows.
Author : Alan M. Rugman
Publisher : OUP Oxford
ISBN 13 : 0191615668
Total Pages : 880 pages
Book Rating : 4.1/5 (916 download)
Download or read book The Oxford Handbook of International Business written by Alan M. Rugman and published by OUP Oxford. This book was released on 2010-08-26 with total page 880 pages. Available in PDF, EPUB and Kindle. Book excerpt: As globalization explodes, so has international business scholarship. This second edition of the Oxford Handbook of International Business synthesises all the relevant literature of the last 40 years in 28 original chapters by the world's most distinguished scholars. Reflecting the changes and development in the field since the first edition this new edition has a changed structure, all the chapters have been updated to take account of the latest scholarship, and five new chapters freshly written. The Handbook is divided into six major sections, providing comprehensive coverage of the following areas: · History and Theory of the Multinational Enterprise · The Political and Regulatory Environment · Strategy and International Management · Managing the MNE · Area Studies · Methodological Issues These state of the art literature reviews will be invaluable references for students in business schools, social sciences, law, and area studies.
