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Transfer Pricing In Canada And The Us Intangible Property In Controlled Transactions
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Book Synopsis Transfer Pricing in Canada and the U.S. : Intangible Property in Controlled Transactions by : R. Robillard
Download or read book Transfer Pricing in Canada and the U.S. : Intangible Property in Controlled Transactions written by R. Robillard and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the author considers some situations in which intangible property can play a key role in determining appropriate transfer prices in accordance with the arm's-length principle.
Book Synopsis U.S. Transfer Pricing Sourcebook by : Amanda Johnson
Download or read book U.S. Transfer Pricing Sourcebook written by Amanda Johnson and published by WorldTrade Executive, Inc.. This book was released on 2005-03 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: U.S. TRANSFER PRICING SOURCEBOOK is a single-volume report designed to advise international finance professionals on the cutting edge tools and techniques being developed and applied by leading consultants. This sourcebook provides strategies on Intercompany Sales, Intercompany Service transactions, Cross-Border licensing, and Cost Sharing agreements.
Book Synopsis The Transfer Pricing of Intangibles by : Michelle Markham
Download or read book The Transfer Pricing of Intangibles written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2005-01-01 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.
Book Synopsis Transfer Pricing in Canada and the United States by : Robert Robillard
Download or read book Transfer Pricing in Canada and the United States written by Robert Robillard and published by Self-Counsel Press. This book was released on 2020-09-15 with total page 131 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this day and age, international expansion or simply conducting commercial dealings across borders, without too many hassles, is a taxing proposal. Without a strong understanding of the laws ruling international taxes, peace of mind is, at best, elusive. This book focuses on the rules of transfer pricing within the international tax regime, as they stand in Canada and the United States. Commercial enterprises large and small will benefit from the expert advice in this book. Author Robert Robillard brings his years of experience as an economist, accountant, and teacher to this work. He explains the background of pricing cross-border transactions between related parties, and offers a “Transfer Pricing Tool Kit” for the design, implementation, and documentation of the value chain for business and taxation purposes. Robillard covers the expected and unexpected relationships that will emerge from the cross-border transactions: the transfer pricing audit and the mechanisms available to remedy double taxation, as well as the usefulness of an advisor with respect to the handling of cross-border transactions.
Book Synopsis Transfer Pricing for Intangibles by : Fred de Hosson
Download or read book Transfer Pricing for Intangibles written by Fred de Hosson and published by Springer. This book was released on 1989-06-06 with total page 94 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of articles on the topic written by various authors, including: "A German tax practitioner's view on the White Paper" by Christoph Bellstedt; "The Italian approach to cost-contribution arrangements and possible discrepancies with the US White Paper on transfer pricing" by Guglielmo Maisto.
Book Synopsis Transfer Pricing and the Arm's Length Principle in International Tax Law by : Jens Wittendorff
Download or read book Transfer Pricing and the Arm's Length Principle in International Tax Law written by Jens Wittendorff and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 914 pages. Available in PDF, EPUB and Kindle. Book excerpt: The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.
Book Synopsis Transfer Pricing in Canada by : François Vincent
Download or read book Transfer Pricing in Canada written by François Vincent and published by . This book was released on 2002 with total page 324 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property by : Melanie Keller
Download or read book An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property written by Melanie Keller and published by GRIN Verlag. This book was released on 2015-07-24 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bachelor Thesis from the year 2015 in the subject Economics - International Economic Relations, Management Center Innsbruck, language: English, abstract: Due to increased globalisation over the last years and enhanced activities of multinational enterprises (MNEs), intra-firm trade has become more and more important. Intra-firm trade is estimated to constitute about one third of the global trade; and about 50% of all exports within the member states of the Organisation for Economic Co-operation and Development (OECD) are intra-firm exports. In order to determine the expenses and revenues for the associated companies, transfer prices (TP) have to be set for the respective goods of intra-group transfers (Organisation for Economic Co-operation and Development [OECD]). Intra-group transfers can be defined as the transaction of tangible or intangible property from one entity of a MNE to another entity, considered as sale and “may apply to departments, divisions, subsidiaries, or affiliate business units” . A TP therefore is the internal monetary value im-posed on goods, services or unmanufactured material that is transferred within a MNE group. According to the OECD (2010) intra-firm transfers are likewise de-fined as controlled transactions (i.e., transactions between two associated enterprises).
Book Synopsis Transfer Pricing Rules and Compliance Handbook by : Marc M. Levey
Download or read book Transfer Pricing Rules and Compliance Handbook written by Marc M. Levey and published by CCH. This book was released on 2006 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book gives an overview of the basic principles of transfer pricing and U.S. transfer pricing rules, and the impact of transfer pricing on other issues such as customs valuation, Section 404 of the Sarbanes-Oxley Act of 2002, and FASB Interpretation no. 48.
Book Synopsis Transactional Adjustments in Transfer Pricing by : Aitor Navarro
Download or read book Transactional Adjustments in Transfer Pricing written by Aitor Navarro and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Introduction to Transfer Pricing by : Jerome Monsenego
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.
Book Synopsis Transfer Pricing in the 1990s by : Roger Y. Tang
Download or read book Transfer Pricing in the 1990s written by Roger Y. Tang and published by Praeger. This book was released on 1993-01-30 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt: The author discusses changes in transfer pricing regulations introduced by the U.S. government and its major trading partners, and gives information (obtained from a survey done in 1990) on U.S. transfer pricing practices, comparing them with those of an earlier study done in 1977.
Book Synopsis Transfer Pricing Handbook by : Robert Feinschreiber
Download or read book Transfer Pricing Handbook written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2001 with total page 1040 pages. Available in PDF, EPUB and Kindle. Book excerpt: This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).
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.
Book Synopsis Arm's Length Transaction Structures by : Andreas Bullen
Download or read book Arm's Length Transaction Structures written by Andreas Bullen and published by . This book was released on 2010 with total page 878 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :United States. Congress. Joint Committee on Internal Revenue Taxation Publisher : ISBN 13 : Total Pages :1510 pages Book Rating :4.3/5 (91 download)
Book Synopsis Income tax conventions by : United States. Congress. Joint Committee on Internal Revenue Taxation
Download or read book Income tax conventions written by United States. Congress. Joint Committee on Internal Revenue Taxation and published by . This book was released on 1962 with total page 1510 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Transfer Pricing written by Mukesh Butani and published by . This book was released on 2007 with total page 1312 pages. Available in PDF, EPUB and Kindle. Book excerpt: Reference guide to the Indian transfer pricing laws and method. The book provides comprehensive coverage and practical guidance on transfer pricing issues, including an analysis of the Indian legislation and transfer pricing methods; documentation requirements; a comparison of the Indian legislation with the OECD guidelines; tax planning techniques related to transfer pricing; discussions of the transfer pricing regime in Australia, Canada, China, France, Germany, Japan, Singapore, the United Kingdom and the United States. Furthermore, it contains brief overviews of the transfer pricing regime in 18 other countries; and the OECD transfer pricing guidelines for multinational enterprises and tax administrations (July 1995).
