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Transfer Pricing Developments Around The World 2019
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Book Synopsis Transfer Pricing Developments Around the World 2019 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2019 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2019-08-09 with total page 294 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 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 papers 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 and Intra-Group Services; Recent Developments on Transfer Pricing and Intra-Group Financing; Recent Developments on the Nexus Rules to Tax Business Profits at Source; and Recent Developments on Attribution of Profits to Digital Permanent Establishments. The intense work of international organizations such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations as well as the intense work of the European Union 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 academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Book Synopsis Transfer Pricing Developments Around the World 2020 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2020 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2020-09-28 with total page 312 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 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 the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union 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 academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Book Synopsis Transfer Pricing Developments around the world 2023 by : Raffaele Petruzzi
Download or read book Transfer Pricing Developments around the world 2023 written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2022-01-13 with total page 275 pages. Available in PDF, EPUB and Kindle. Book excerpt: Information Law Series #48 About this book: Imposing Data Sharing among Private Actors is a vital book shedding light on the nature of certain economic and societal balancing exercises required for any compulsory business-to-business (B2B) data-sharing initiatives because data sharing involves both benefits and potential costs. While the economic value originating from data sharing seems evident, identifying the legal framework to be applied to it is a challenge. This is due to the multiple claims and rights aimed at controlling, accessing or benefiting from data processing. What’s in this book: Whether these initiatives pursue economic, societal or empowerment objectives, their potential benefits must be balanced with the following three considerations that are extensively investigated in the book: the economic interests of the data holder; personal data protection considerations; and long-term and collective costs in terms of individual autonomy. The analysis elucidates how these aspects have been factored into existing compulsory B2B data-sharing initiatives so far (particularly in Europe), and on how they may be used as a source of inspiration in future initiatives. Insightful suggestions on the implementation of these balancing exercises conclude the volume. How this will help you: Based on law and literature in competition, personal data protection and intellectual property, the book greatly highlights the necessary balances underlying compulsory B2B data sharing and raises awareness about the crucial need to take the risks involved into consideration. It will be highly appreciated by policymakers, academics and private actors interested in issues linked to competition law in the digital environment, regulation of platforms, data governance or the interaction between competition law and personal data protection law.
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 Developments around the World 2024 by : Raffaele Petruzzi
Download or read book Transfer Pricing Developments around the World 2024 written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2024-09-19 with total page 277 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 policymakers, 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 seven topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, it encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing and Amount B; Transfer Pricing and BEFIT; The EC’s Transfer Pricing Directive Proposal; Transfer Pricing and Profit Attribution to New-Age Permanent Establishments; Transfer Pricing and ESG; and Transfer Pricing and New Technologies. The intense work of international organizations, such as the OECD, the UN, and the EU, is thoroughly analysed 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, government officials and tax lawyers, in-house counsel, and interested academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Book Synopsis Transfer Pricing Developments Around the World 2017 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2017 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: Derived from the renowned multi-volume International Encyclopaedia of Laws, this book describes the social security regime in Slovenia. It conveys a clear working knowledge of the legal mechanics affecting health care, employment injuries and occupational diseases, incapacity to work, pensions, survivors’ benefits, unemployment benefits and services, and family benefits. The analysis covers the field of application, conditions for entitlement, calculation of benefits, financing, the institutional framework, and relevant law enforcement and controls. Allowances for retirees, employees, public sector workers, the self-employed, and the handicapped are all clearly explained, along with full details of claims, adjudication procedures, and appeals. Succinct yet eminently practical, the book will be a valuable resource for lawyers handling social security matters in Slovenia. It will be of practical utility to those both in public service and private practice called on to develop and to apply social security law and policy, and of special interest as a contribution to the comparative study of social security systems.
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.
Book Synopsis Transfer Pricing Developments Around the World 2018 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2018 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2018-08-21 with total page 282 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 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 seven topic-based papers prepared by international experts on transfer pricing. Greatly helping to define where the line should be drawn to distinguish genuine transfer pricing issues from other anti-avoidance measures, 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 documentation and country-by-country reporting; • recent developments on comparability analysis in transfer pricing; and • recent developments on the profit split method. The intense work of international organizations such as the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund, and other international organizations 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 an efficient dialogue and coordinated approach to transfer pricing in the future.
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 Transfer Pricing and Developing Economies by : Joel Cooper
Download or read book Transfer Pricing and Developing Economies written by Joel Cooper and published by World Bank Publications. This book was released on 2017-01-05 with total page 275 pages. Available in PDF, EPUB and Kindle. Book excerpt: Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.
Book Synopsis Fundamentals of Transfer Pricing by : Michael Lang
Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2021-06-18 with total page 484 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.
Book Synopsis Attribution of Profits to Permanent Establishments by : Michael Lang
Download or read book Attribution of Profits to Permanent Establishments written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2020-04-08 with total page 164 pages. Available in PDF, EPUB and Kindle. Book excerpt: Attribution of Profits to Permanent Establishments: Issues and Developments The profit attribution to permanent establishments is one of the most controversial topics in international tax law. In recent years it was subject to various changes based on the introduction of the “Authorized OECD Approach” in 2008 and 2010, the outcomes of Final Report on OECD BEPS Action 7 and the Final Report on “Additional Guidance on the Attribution of Profits to a Permanent Establishment under BEPS Action 7” from 2018 (with the previous Discussion-Drafts). This publication discusses the most important issues and recent developments related to the attribution of profits to permanent establishments. Starting with an in-depth analysis on the commonalities and differences between the profit attribution provisions in modern double tax treaties (ie Art 7 AOA vs Art 9 OECD/UN Models), it further deals with topics such as profit attribution to PEs and PE exemptions (Art 5 para 4), profit attribution to agency PEs (Art 5 para 5 and 6), and profit attribution to a "significant economic presence" and to market states. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium that took place in October 2019 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the opinions on the issues at stake of representatives of tax administrations, multinationals and tax advisories, which completes this essential practical guideline.
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 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.
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.
Book Synopsis Taxing Multinationals by : Lorraine Eden
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.
Book Synopsis World Development Report 2019 by : World Bank
Download or read book World Development Report 2019 written by World Bank and published by World Bank Publications. This book was released on 2018-10-31 with total page 201 pages. Available in PDF, EPUB and Kindle. Book excerpt: Work is constantly reshaped by technological progress. New ways of production are adopted, markets expand, and societies evolve. But some changes provoke more attention than others, in part due to the vast uncertainty involved in making predictions about the future. The 2019 World Development Report will study how the nature of work is changing as a result of advances in technology today. Technological progress disrupts existing systems. A new social contract is needed to smooth the transition and guard against rising inequality. Significant investments in human capital throughout a person’s lifecycle are vital to this effort. If workers are to stay competitive against machines they need to train or retool existing skills. A social protection system that includes a minimum basic level of protection for workers and citizens can complement new forms of employment. Improved private sector policies to encourage startup activity and competition can help countries compete in the digital age. Governments also need to ensure that firms pay their fair share of taxes, in part to fund this new social contract. The 2019 World Development Report presents an analysis of these issues based upon the available evidence.
