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Transfer Pricing Risks Post Beps A Practical Guide
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Book Synopsis Transfer Pricing Risks Post-BEPS: A Practical Guide by : Fabrizio Lolliri
Download or read book Transfer Pricing Risks Post-BEPS: A Practical Guide written by Fabrizio Lolliri and published by Tolley. This book was released on 2017-12-12 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing has never had as much media exposure as last year and keeps showing up on the headlines of all major newspapers and other media. Political pressure and the increasing government deficit that is affecting most of the countries are putting a lot of pressure on tax authorities worldwide to fill in the budget gap and are driving a more aggressive and inquisitive approach towards tax payers. The OECD embarked on a very difficult mission with its Base Erosion and Profit Shifting ("BEPS") project, which started with the G20 in 2012. The world of Transfer Pricing as we know it is changing as the BEPS project continues to raise new issues with the existing structures setup by large multinational and often driven by the desire to achieve better tax efficiency. Although, the BEPS project is well advanced, only few countries have already issued new legislation and amendments to transfer pricing regulations to comply with the new principles from the BEPS project. The lack of clarity on how BEPS will translate in all the different jurisdictions is a concern for not just tax directors, but also CEOs and CFOs. Transfer Pricing Risks Post-BEPS: A Practical Guide explores the issues raised by the BEPS project and offers the readers a practical approach to risk assessment and mitigation in preparation for new legislation and rules to come. The readers are also guided through how supply chain planning is likely to change in the future and how businesses can still ensure their vision and strategy can be implemented whilst minimising risk and improving efficiencies that go hand in hand with real commercial planning.
Book Synopsis Transfer Pricing in One Lesson by : Oliver Treidler
Download or read book Transfer Pricing in One Lesson written by Oliver Treidler and published by . This book was released on 2020 with total page 138 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm's length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book's content is applicable to a global context.
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 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 2019-01-03 with total page 500 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint 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), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.
Book Synopsis Transfer Pricing in One Lesson by : Oliver Treidler
Download or read book Transfer Pricing in One Lesson written by Oliver Treidler and published by Springer Nature. This book was released on 2019-09-12 with total page 145 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm’s length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book’s content is applicable to a global context.
Book Synopsis Intercompany Agreements for Transfer Pricing Compliance by : Paul Sutton
Download or read book Intercompany Agreements for Transfer Pricing Compliance written by Paul Sutton and published by . This book was released on 2019-03-11 with total page 146 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a practical resource for finance, tax and transfer pricing professionals, and for anyone involved in designing, implementing, maintaining or reviewing intercompany agreements for multinational groups.
Book Synopsis Transfer Pricing Handbook by : Mark Loveday
Download or read book Transfer Pricing Handbook written by Mark Loveday and published by . This book was released on 2013-10 with total page 118 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Transfer Pricing written by Mark Loveday and published by . This book was released on 2019 with total page 209 pages. Available in PDF, EPUB and Kindle. Book excerpt: The revised transfer pricing regime created by the 2018 BEPs changes together with changes in focus and practice by Inland Revenue have resulted in substantial changes to our transfer pricing landscape. Companies with overseas affiliates will invariably need to consider their intra-group dealings and the extent to which they may need to analyse and justify to a tax authority the transfer pricing related to these dealings. Written by transfer pricing specialist Mark Loveday, Transfer Pricing is designed to provide readers with a practical understanding of the fundamentals of transfer pricing and the issues surrounding it. New Zealand companies with offshore parents or subsidiaries will find the book invaluable.
Book Synopsis Transfer Pricing in the US by : Felix I. Lessambo
Download or read book Transfer Pricing in the US written by Felix I. Lessambo and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transfer Pricing in the US by : Felix I. Lessambo
Download or read book Transfer Pricing in the US written by Felix I. Lessambo and published by . This book was released on 2017 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: This concise, practical guide to the latest issues in the rapidly evolving legal regime on transfer pricing in the US context fills the need to gain a firm grasp of transfer pricing rules and practice for corporate counsel and practitioners worldwide, enabling them to prepare compliant solutions and strategies and avoid pitfalls. The book begins with a general introduction to transfer pricing and then discusses the current OECD's Transfer Pricing Guidelines, which form the basis for most transfer pricing rules around the world. The book describes in detail the approved methods for tangible and intangible property, cost sharing, services and the best method rule. Then the book discusses functional analysis for the various methods, including the necessary documentation and penalty rules. This book is an indispensable resource for practitioners and academics, and it will be very useful to state tax authorities.
Book Synopsis Global Transfer Pricing by : John Henshall
Download or read book Global Transfer Pricing written by John Henshall and published by Bloomsbury Publishing. This book was released on 2016-01-01 with total page 289 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an introduction to transfer pricing as it is practiced today, including the recent changes to the OECD transfer pricing guidance following the Base Erosion and Profit Shifting (BEPS) initiative. It also explains how to implement transfer pricing models in global multinationals, how to monitor transactions to ensure compliance and how to create transfer pricing documentation. This edition has been revised to cover the 2015 OECD BEPS report on Action 8-19 and Action 13, released in September 2015. The book examines, among others: types of transactions (tangible goods and intra-group services); financing; intangible property; profit split; business restructuring; transfer pricing documentation; operational transfer pricing; tax audits and eliminating double taxation and UK transfer pricing legislation.
Book Synopsis United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 by : United Nations
Download or read book United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 written by United Nations and published by . This book was released on 2017 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.
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 608 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 OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 13.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-19 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
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 659 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 Transfer Pricing and Intra-group Financing by : Anuschka Bakker
Download or read book Transfer Pricing and Intra-group Financing written by Anuschka Bakker and published by IBFD. This book was released on 2012 with total page 593 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
