Transfer Pricing In The 1990s

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The Transfer Pricing of Intangibles

Author : Michelle Markham
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041123687
Total Pages : 360 pages
Book Rating : 4.0/5 (411 download)

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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.

Transfer Pricing for Financial Institutions

Author : John Smullen
Publisher : Woodhead Publishing
ISBN 13 : 9781855733725
Total Pages : 168 pages
Book Rating : 4.7/5 (337 download)

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Book Synopsis Transfer Pricing for Financial Institutions by : John Smullen

Download or read book Transfer Pricing for Financial Institutions written by John Smullen and published by Woodhead Publishing. This book was released on 2001-07-17 with total page 168 pages. Available in PDF, EPUB and Kindle. Book excerpt: A cutting-edge study of transfer pricing in the increasingly competitive financial services sector. It examines the many issues involved and suggests different techniques for establishing efficient transfer pricing systems. This book is essential reading for all organisations that raise and loan funds in today's global markets.

Introduction to Transfer Pricing

Author : Jerome Monsenego
Publisher :
ISBN 13 : 9789144092706
Total Pages : 163 pages
Book Rating : 4.0/5 (927 download)

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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.

Department of the Treasury's Report on Issues Related to the Compliance with U.S. Tax Laws by Foreign Firms Operating in the United States

Download Department of the Treasury's Report on Issues Related to the Compliance with U.S. Tax Laws by Foreign Firms Operating in the United States PDF Online Free

Author : United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight
Publisher :
ISBN 13 :
Total Pages : 176 pages
Book Rating : 4.0/5 ( download)

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Book Synopsis Department of the Treasury's Report on Issues Related to the Compliance with U.S. Tax Laws by Foreign Firms Operating in the United States by : United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight

Download or read book Department of the Treasury's Report on Issues Related to the Compliance with U.S. Tax Laws by Foreign Firms Operating in the United States written by United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight and published by . This book was released on 1992 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Tax Transfer Pricing

Author : Andrea Musselli
Publisher : Gruppo 24 Ore
ISBN 13 :
Total Pages : 446 pages
Book Rating : 4.2/5 (548 download)

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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”.

Transfer Pricing and the Arm's Length Principle in International Tax Law

Author : Jens Wittendorff
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041132708
Total Pages : 914 pages
Book Rating : 4.0/5 (411 download)

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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.

Current Trends and Corporate Cases in Transfer Pricing

Author : Roger Y. Tang
Publisher : Praeger
ISBN 13 :
Total Pages : 208 pages
Book Rating : 4.E/5 ( download)

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Book Synopsis Current Trends and Corporate Cases in Transfer Pricing by : Roger Y. Tang

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.

Transfer Pricing and Value Creation

Author : Raffaele Petruzzi
Publisher : Linde Verlag GmbH
ISBN 13 : 3709410371
Total Pages : 556 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Transfer Pricing and Value Creation by : Raffaele Petruzzi

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 556 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.

Resolving Transfer Pricing Disputes

Author : Eduardo Baistrocchi
Publisher : Cambridge University Press
ISBN 13 : 1139916289
Total Pages : 975 pages
Book Rating : 4.1/5 (399 download)

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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.

International and Comparative Taxation:Essays in Honour of Klaus Vogel

Author : Klaus Vogel
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041198415
Total Pages : 284 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis International and Comparative Taxation:Essays in Honour of Klaus Vogel by : Klaus Vogel

Download or read book International and Comparative Taxation:Essays in Honour of Klaus Vogel written by Klaus Vogel and published by Kluwer Law International B.V.. This book was released on 2002-09-03 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of the 16 English language contributions of "Staaten und Steuern (States and Taxes)", the original festschrift to honour Klaus Vogel.

Transfer Pricing Audits in China

Author : J. Li
Publisher : Springer
ISBN 13 : 0230595812
Total Pages : 204 pages
Book Rating : 4.2/5 (35 download)

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Book Synopsis Transfer Pricing Audits in China by : J. Li

Download or read book Transfer Pricing Audits in China written by J. Li and published by Springer. This book was released on 2007-01-10 with total page 204 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book focuses on the practice of transfer pricing audits which the Chinese government operates in the case of the vast number of foreign enterprises operating in the Chinese economy. It includes the testimony of Chinese officials about their work, material that given the secrecy of Chinese business and culture, is difficult to come by.

Privatization and Transition in Russia in the Early 1990s

Author : Carol Scott Leonard
Publisher : Routledge
ISBN 13 : 113502166X
Total Pages : 206 pages
Book Rating : 4.1/5 (35 download)

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Book Synopsis Privatization and Transition in Russia in the Early 1990s by : Carol Scott Leonard

Download or read book Privatization and Transition in Russia in the Early 1990s written by Carol Scott Leonard and published by Routledge. This book was released on 2013-06-19 with total page 206 pages. Available in PDF, EPUB and Kindle. Book excerpt: Few economic events have caused such controversy as the privatization process in Russia. Some see it as the foundation of political and economic freedom. For others it was economics gone wrong, and ended in "Russians stealing money from their own country". As Russia reasserts itself, and its new brand of capitalism, it is ever more important that policy makers and scholars understand the roots of the economic structure and governance of that country; what was decided, who made the decisions and why, what actually transpired, and what implications this has for the future of Russia. This work, written by two senior advisors to the Russian government, has unique access to documentation, tracking the decision making process in the Russian Mass Privatization process. By close reference to events, and supplemented by interviews with many of the key participants, it shows that the policies adopted were often influenced and shaped by different forces than those cited by current popular accounts. The book challenges the interpretation of Russian privatization by some of the West’s most eminent economists. It underlines that economists of all schools, who bring assumptions from the West to the analysis of Russia, may reach false or misleading conclusions. It is an essential guide for anyone interested in Russian economic reform, and anyone who seeks to understand this enigmatic country, and its actions today.

INTERNATIONAL ACCOUNTING

Author : A. K. DAS MOHAPATRA
Publisher : PHI Learning Pvt. Ltd.
ISBN 13 : 812034572X
Total Pages : 422 pages
Book Rating : 4.1/5 (23 download)

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Book Synopsis INTERNATIONAL ACCOUNTING by : A. K. DAS MOHAPATRA

Download or read book INTERNATIONAL ACCOUNTING written by A. K. DAS MOHAPATRA and published by PHI Learning Pvt. Ltd.. This book was released on 2012-04-13 with total page 422 pages. Available in PDF, EPUB and Kindle. Book excerpt: The second edition of this well-received book is fully updated to equip students with international accounting standards, regulations and financial reporting. Written in sync with the changing accounting practices the world over, this text provides comprehensive coverage of the core concepts of international accounting and their applications, with detailed discussion on international financial management which has gained importance over recent years due to globalization and liberalization. The text also traces the genesis of international accounting, and discusses at length topics such as foreign currency translation, consolidation of foreign financial statements, transfer pricing, international taxation and financial reporting practices in leading countries such as USA, UK, Canada and Germany. Intended primarily as a text for the postgraduate students of financial studies such as MFC, Commerce, and International Business (MIB), postgraduate students of management specializing in finance, this accessible text can also be used for professional courses like CA and ICWA. NEW TO THIS EDITION : Explains International Financial Reporting Standards (IFRS) and its implementation. Includes four new chapters (Chapters 11–14) on international financial management, foreign exchange forecast, measurement and management of foreign exchange exposure to enlarge the scope of the book. Provides key terms at the end of each chapter for better comprehension. KEY FEATURES : Comparative analyses in line with the IAS, AS and the US Accounting Standards/GAAP Tabular representation of ideas/concepts for clear understanding Large number of worked-out examples provided in a graded manner to illustrate the concepts Review questions at ends of chapters Exhaustive glossary at the end of the book

Information Technology and the Corporation of the 1990s

Author : Thomas J. Allen
Publisher : Oxford University Press
ISBN 13 : 0195361784
Total Pages : 545 pages
Book Rating : 4.1/5 (953 download)

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Book Synopsis Information Technology and the Corporation of the 1990s by : Thomas J. Allen

Download or read book Information Technology and the Corporation of the 1990s written by Thomas J. Allen and published by Oxford University Press. This book was released on 1994-01-06 with total page 545 pages. Available in PDF, EPUB and Kindle. Book excerpt: One of the most pathbreaking and influential business books of the 1990s is The Corporation of the 1990s by Michael Scott Morton. Its expert view of how information technology would influence organizations and their ability to survive and prosper in the 1990s has become the benchmark of thinking about information technology. Now, in a supporting companion volume, Information Technology and the Corporation of the 1990s makes available the research on which The Corporation of the 1990s was based. The research was conducted at the Sloan School of Management at MIT by the Management in the 1990s program. The program was funded by a group of 12 industrial and government sponsors from the United States and Britain which included American Express, Digital Equipment Corporation, Eastman Kodak, British Petroleum, MCI Communications, General Motors, U.S. Army, ICL Ltd., Internal Revenue Service, Ernst & Young, BellSouth, and CIGNA Corporation. Information Technology and the Corporation of the 1990s aims to disseminate ideas on how organizations can manage the impact of information technology, and also to raise issues and stimulate further thought by both academics and professionals. The book is divided into three sections which cover the information technology revolution, strategic options, and organization and management responses. It incorporates the work of many important scholars including Charles Jonscher, Michael J. Piore, Thomas W. Malone. JoAnne Yates, Robert I. Benjamin, Gary W. Loveman, Eric von Hippel, Edgar H. Schein, Stanley M. Besen, Garth Saloner, N. Venkatraman, Akbar Zaheer, John C. Henderson, Jay C. Cooprider, Kevin Crowston, Jeongsuk Koh, Gordon Walker, Laura Poppo, John S. Carroll, Constance Perin, Brian T. Pentland, John Chalykoff, Lotte Bailyn, D. Eleanor Westney, Sumantra Ghoshal, John D.C. Little, Thomas J. Allen, Oscar Hauptman, Lisa M. Lynch, Paul Osterman, Thomas A. Kochan, and John Paul MacDuffie.

Draining development?

Author : Peter Reuter
Publisher : World Bank Publications
ISBN 13 : 0821389327
Total Pages : 553 pages
Book Rating : 4.8/5 (213 download)

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Book Synopsis Draining development? by : Peter Reuter

Download or read book Draining development? written by Peter Reuter and published by World Bank Publications. This book was released on 2012-02-01 with total page 553 pages. Available in PDF, EPUB and Kindle. Book excerpt: A growing concern among those interested in economic development is the realization that hundreds of billions of dollars are illicitly flowing out of developing countries to tax havens and other financial centers in the developed world. This volume assesses the dynamics of these flows, much of which is from corruption and tax evasion.

Present Law and Certain Issues Relating to Transfer Pricing (code Section 482)

Author :
Publisher :
ISBN 13 :
Total Pages : 48 pages
Book Rating : 4.3/5 (121 download)

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Book Synopsis Present Law and Certain Issues Relating to Transfer Pricing (code Section 482) by :

Download or read book Present Law and Certain Issues Relating to Transfer Pricing (code Section 482) written by and published by . This book was released on 1990 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt:

International Bibliography of the Social Sciences

Author : British Library of Political and Economic Science
Publisher : Psychology Press
ISBN 13 : 9780415074575
Total Pages : 704 pages
Book Rating : 4.0/5 (745 download)

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Book Synopsis International Bibliography of the Social Sciences by : British Library of Political and Economic Science

Download or read book International Bibliography of the Social Sciences written by British Library of Political and Economic Science and published by Psychology Press. This book was released on 1992 with total page 704 pages. Available in PDF, EPUB and Kindle. Book excerpt: The IBSS is the essential tool for librarians, university departments, research institutions and any public or private institution whose work requires access to up-to-date and comprehenisve knowledge of the social sciences.