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Author :
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (138 download)
Download or read book Using Advance Pricing Agreements to Mitigate Transfer Pricing Risk written by and published by . This book was released on 2008 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Michelle Markham
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041140727
Total Pages : 408 pages
Book Rating : 4.0/5 (411 download)
Download or read book Advance Pricing Agreements written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2012-06-28 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing (the pricing of cross-border intra-firm transactions between related parties) is now the top international tax issue faced by multinational enterprises. In an international taxation environment characterized by rigorous enforcement of transfer pricing documentation, disclosure, and audit processes, a need has arisen for multinationals to be cognizant of the impact of their ‘tax risk appetite’ on their relationship with taxation authorities and to be aware of how best to manage their transfer pricing arrangements. The most promising development has been the growing commitment to Advance Pricing Agreements (APAs) – arrangements made prospectively between a multinational taxpayer and one or more revenue authorities, agreeing on an appropriate set of criteria for the determination of the transfer pricing of the covered transactions over a period of time. This is the first book to offer expert insights on APAs from a practical perspective. By focusing on the United States and Australia, the two countries that were at the forefront of adopting APAs and whose wealth of experience over two decades confirms their APA programs as the global paradigms, the author is able to highlight the advantages and disadvantages of pursuing an APA and to shed light on the powerful efficacy of this strategy for avoiding transfer pricing disputes. In addition, the author enlists the views of revenue authorities, transfer pricing practitioners, and corporate counsel who deal with the realities of transfer pricing assessment and compliance on an ongoing basis, offering acute insight into how APAs really work in a practical way. This book contributes to the body of knowledge on APAs in the context of transfer pricing by providing in-depth scrutiny of the most important issues surrounding this critical area, and by examining innovations in APAs in the United States and in Australia. Its unmatched coverage will be welcomed by tax experts at law firms and multinational companies as well as by revenue officials, policymakers, and scholars and researchers in international taxation.
Author : Ernst & Young International
Publisher :
ISBN 13 :
Total Pages : 30 pages
Book Rating : 4.:/5 (222 download)
Download or read book Transfer Pricing written by Ernst & Young International and published by . This book was released on 1995 with total page 30 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264169466
Total Pages : 110 pages
Book Rating : 4.2/5 (641 download)
Download or read book Dealing Effectively with the Challenges of Transfer Pricing written by OECD and published by OECD Publishing. This book was released on 2012-01-18 with total page 110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report addresses the practical administration of transfer pricing programmes by tax administrations.
Author : Robert T. Cole
Publisher : Aspen Publishers
ISBN 13 :
Total Pages : 1302 pages
Book Rating : 4.0/5 ( download)
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.
Author : Oliver Treidler
Publisher : BoD – Books on Demand
ISBN 13 : 3757835638
Total Pages : 76 pages
Book Rating : 4.7/5 (578 download)
Download or read book Transfer Pricing Survival Guide written by Oliver Treidler and published by BoD – Books on Demand. This book was released on 2023-04-19 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer Pricing is an issue that has material implications for tax risks faced by MNEs. Yet, pragmatic guidance on identifying and managing transfer pricing risk is lacking. Consequently, CFOs and other stakeholders tend to underestimate risks while overestimating the costs for mitigating such risks. The first objective of the Survival Guide is to shed light on typical transfer pricing risks and provide an intuitive "risk matrix" that is designed to help CFOs as well as tax advisors to develop a quantitative understanding of the relevant risks. The second objective is to outline targeted mitigation strategies. The mitigation strategies outlined in the Survival Guide are based on pragmatic considerations rather than complex analysis. The aim is to provide you with concise explanations and help you to differentiate between tasks that are considered a "must" for mitigation purposes and those that can be regarded as merely "nice to have" The immediate utilization of the Survival Guide is as a frame of reference for making informed decisions about the scope and target of your transfer pricing projects. The Survival Guide presents a framework for thinking about transfer pricing risk that will also benefit tax professionals as well as academics with an interest in understanding the nature of transfer pricing risks.
Author : William H. Byrnes
Publisher :
ISBN 13 : 9781522190059
Total Pages : pages
Book Rating : 4.1/5 (9 download)
Download or read book Practical Guide to U.S. Transfer Pricing written by William H. Byrnes and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The new 4th Edition of Practical Guide to U.S. Transfer Pricing continues to be the authoritative legal treatise for tax counsel, tax authorities, the judiciary, and policy makers. The 4th Edition is fully revised with several new chapters, over 2,000 pages of analyses and practice notes, 47 chapters divided over six parts. Part I: U.S. regulatory analysis, application of transfer pricing methods, and jurisprudence; Part II: OECD; Part III: United Nations; Part IV: European Union; Part V: Industry topics; and Part VI: Country practice and tax risk management.Professor Byrnes brings together 50 of the industry's eminent transfer pricing counsel, economists, and financial accountants to provide a comprehensive two-volume "go-to" resource for tax risk management.Within the first 29 chapters, the U.S. Treasury regulations and jurisprudence are analyzed from an advisory perspective, including chapters on the transfer pricing methods, documentation and examination, advance pricing agreements and mutual assistance, litigation, state issues, and customs. A chapter is dedicated to analyzing the transfer pricing aspects of each step of a U.S. business restructuring.The next six chapters of Part II address the OECD's approach to transfer pricing because many OECD member as well as nonmember countries refer to the OECD Transfer Pricing Guidelines as authoritative or persuasive. The U.S. Treasury refers to the OECD Guidelines for purposes of mutual agreement procedures between competent authorities of treaty partners. These chapters include an exemplary application of value chain analysis, digitalization's impact on transfer pricing compliance, and hybrid rules interaction with transfer pricing.Part III is reserved for future chapters analyzing the UN Transfer Pricing Manual and UN transfer pricing guidance for extractive industries because many subscribers have operations in developing economies. Part VI includes a chapter on the impact of EU State Aid cases on APAs. Part V includes nine industry specific chapters: two risk management chapters, five chapters for financial services topics, and two chapters providing case studies to examine the global value chain of an industry. Part VI contains two country chapters analyzing the national transfer pricing regulations and practice of Brazil and India. Parts II through Part VI will expand each year to include further analysis and case study chapters.
Author : Elizabeth King
Publisher : Springer Science & Business Media
ISBN 13 : 0306482185
Total Pages : 294 pages
Book Rating : 4.3/5 (64 download)
Download or read book Transfer Pricing and Valuation in Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2007-05-08 with total page 294 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer Pricing and Valuation in Corporate Taxation analyzes the disparities between both federal statutes and regulations, and r- ulations and administrative practice, in a highly controversial area of corporate tax policy: intra-company transfer pricing for tax p- poses. It addresses issues that often mean millions of dollars to in- vidual corporations, and a significant fraction of the federal gove- ment’s revenue base. These disparities between law, regulations, and administrative practice are concerning on a number of grounds. First, they - pose considerable economic costs by inducing corporations to engage in a variety of “rent-seeking” activities designed to reduce their - pected tax liabilities, and by requiring the IRS to devote still more to enforcement efforts that are very often futile. Second, they are in- ; herently undemocratic. Administrative practice is currently ad hoc by relying on dispute resolution procedures that can and do yield very different settlements on disputed tax issues from one case to another, the IRS often ends up treating similarly situated cor- rations very differently. Moreover, to the extent that the disp- ity between statute and implementation reflects the IRS’s failure to carry out Congress’ will, the laws passed by duly elected officials are effectively being superseded by administrative procedure, developed incrementally by individuals who are not answerable to an electorate.
Author : Marc M. Levey
Publisher : CCH
ISBN 13 : 9780808015536
Total Pages : 232 pages
Book Rating : 4.0/5 (155 download)
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.
Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403517247
Total Pages : 484 pages
Book Rating : 4.4/5 (35 download)
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.
Author : Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403540338
Total Pages : 261 pages
Book Rating : 4.4/5 (35 download)
Download or read book Transfer Pricing and Financing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 261 pages. Available in PDF, EPUB and Kindle. Book excerpt: In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions: loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law. Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.
Author : Joel Cooper
Publisher : World Bank Publications
ISBN 13 : 1464809704
Total Pages : 275 pages
Book Rating : 4.4/5 (648 download)
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.
Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 940352393X
Total Pages : 312 pages
Book Rating : 4.4/5 (35 download)
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.
Author : Amanda Johnson
Publisher : WorldTrade Executive, Inc.
ISBN 13 : 9781893323698
Total Pages : 124 pages
Book Rating : 4.3/5 (236 download)
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.
Author : Philip W. Carmichael
Publisher : Wiley
ISBN 13 : 9781119157113
Total Pages : 0 pages
Book Rating : 4.1/5 (571 download)
Download or read book Transfer Pricing written by Philip W. Carmichael and published by Wiley. This book was released on 2025-07-01 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Improve corporate profits through alternative transfer pricing strategies Transfer Pricing: Alternative Practical Strategies presents a case study based upon a fictional company to showcase the preparation of a transfer pricing study that meets regulatory needs. This case study focuses on three alternative strategies to transfer pricing: advance pricing agreements, cost sharing agreements, and the use of joint ventures. The advance pricing section considers the factors to take into account when deciding whether this is the right approach, and details the elements that impact the steps you take at each stage of the APA process, such as the prefiling conference, application submission, and more. The section on cost sharing arrangements presents methods for developing and documenting a qualified cost sharing arrangement, as well as buy-in and buy-out payments, international acceptance of cost sharing arrangements, and more. Finally, the international joint ventures section analyzes, among other things, key tax planning issues, such as sham treatment, taxation of operating income, etc. Transfer pricing is the process of pricing goods or services that are being sold within an entity—either between company divisions or departments or between a parent company and a subsidiary. The right transfer pricing model can prove profitable for your organization. Explore which alternative methods—advance pricing agreements, cost sharing agreements, or joint ventures—are best for your business Access information that guides you in improving corporate profits through targeted transfer pricing methodology Consider new ideas in context through a case study that applies presented concepts to a fictional company Leverage an ancillary test bank to reinforce key ideas Transfer Pricing: Alternative Practical Strategies gives you an overview of what transfer pricing is, and offers three strategies that you can leverage to improve corporate profits when determining transfer pricing models.
Author : Michael F. Patton
Publisher :
ISBN 13 : 9781633592704
Total Pages : pages
Book Rating : 4.5/5 (927 download)
Download or read book Transfer Pricing written by Michael F. Patton and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Alan Paisey
Publisher : Universal-Publishers
ISBN 13 : 1612335497
Total Pages : 152 pages
Book Rating : 4.6/5 (123 download)
Download or read book Transfer Pricing written by Alan Paisey and published by Universal-Publishers. This book was released on 2012 with total page 152 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book offers an introduction to transfer pricing with particular reference to China, for those who are looking for an overview that can be rapidly comprehended and who value diagrammatic images as a vehicle for learning. The subject is of importance both for Chinese and foreign personnel engaged in foreign company activity in China and for those who are similarly engaged in Chinese-owned companies already operating abroad, or which are to be extended to foreign locations.
