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Advance Pricing Agreements And Covid 19
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Book Synopsis The Impact of the COVID-19 Pandemic on Advance Pricing Agreements by : B. Gibert
Download or read book The Impact of the COVID-19 Pandemic on Advance Pricing Agreements written by B. Gibert and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The COVID-19 pandemic may impact transfer pricing policies applied within multinational groups. As a result, one could legitimately wonder whether the pandemic could also impact advance pricing agreements (APAs) either concluded or under discussion between tax administrations and enterprises. This question is of foremost importance given that the terms and conditions of APAs are set to ensure tax certainty. In such circumstances, taxpayers could examine how potential changes triggered by the COVID-19 pandemic could impact APAs (section 1.) and what the procedural impact of the COVID-19 pandemic would be on APAs concluded or under discussion (section 2.).
Book Synopsis Advance Pricing Agreements and COVID-19 by : S.F. Foley
Download or read book Advance Pricing Agreements and COVID-19 written by S.F. Foley and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors explain how recent changes to the U.S. advance pricing agreement (APA) model confirm the potential to amend existing APAs and highlight the value of the APA process to address extraordinary economic disruption through tailored long-term solutions.
Book Synopsis Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic by :
Download or read book Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic written by and published by . This book was released on 2020 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: In response to the COVID-19 crisis, a number of tax administrations have already published domestic guidance on some of the transfer pricing implications of COVID-19. While this is an important first step in setting taxpayer expectations, facilitating co-operative compliance and delivering greater tax certainty, the two-sided nature of transfer pricing means that it is only by agreeing a common approach that tax administrations can enhance tax certainty. This Guidance clarifies and illustrates the practical application of the arm's length principle as articulated in the OECD Transfer Pricing Guidelines to the unique fact patterns and specific challenges implied by the COVID-19 pandemic. Four priority issues were identified and are covered in the Guidance: (i) comparability analysis; (ii) losses and the allocation of COVID-19 specific costs; (iii) government assistance programmes; and (iv) advance pricing agreements (APAs). This Guidance was developed and approved by the 137 members of the OECD/G20 Inclusive Framework on BEPS. While it is recognised that some Inclusive Framework members may also follow the United Nations Practical Manual on Transfer Pricing for Developing Countries (2017), this Guidance should be helpful in such circumstances where the UN Manual follows a similar analytical framework and allows for similar conclusions as the OECD Transfer Pricing Guidelines.
Book Synopsis Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic by : Organisation for Economic Co-operation and Development
Download or read book Guidance on the Transfer Pricing Implications of the COVID-19 Pandemic written by Organisation for Economic Co-operation and Development and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Impact of COVID-19 on Transfer Pricing : Issues Arising During the Economic Downturn and Possible Solutions by : M. Cataldi
Download or read book The Impact of COVID-19 on Transfer Pricing : Issues Arising During the Economic Downturn and Possible Solutions written by M. Cataldi and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article analyses whether limited-risk entities may bear under arm's length conditions a portion of the negative financial consequences deriving from the current COVID-19 disruption. Furthermore, the article offers an overview of the impacts of the COVID-19 emergency on the benchmark analyses for 2020, on transfer pricing documentation and on unilateral and bilateral advance pricing agreement (APA) procedures.
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 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.
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.
Author :National Academies of Sciences, Engineering, and Medicine Publisher :National Academies Press ISBN 13 :0309676908 Total Pages :81 pages Book Rating :4.3/5 (96 download)
Book Synopsis Rapid Expert Consultations on the COVID-19 Pandemic by : National Academies of Sciences, Engineering, and Medicine
Download or read book Rapid Expert Consultations on the COVID-19 Pandemic written by National Academies of Sciences, Engineering, and Medicine and published by National Academies Press. This book was released on 2020-05-30 with total page 81 pages. Available in PDF, EPUB and Kindle. Book excerpt: In response to a request from the Office of Science and Technology Policy and the Office of the Assistant Secretary for Preparedness and Response, the National Academies of Sciences, Engineering, and Medicine convened a standing committee of experts to help inform the federal government on critical science and policy issues related to emerging infectious diseases and other 21st century health threats. This set of Rapid Expert Consultations are the first of their kind and represent the best evidence available to the Committee at the time each publication was released. The science on these issues is continually evolving, and the scientific consensus the Committee reaches on these topics will likely evolve with it. The standing committee includes members with expertise in emerging infectious diseases, public health, public health preparedness and response, biological sciences, clinical care and crisis standards of care, risk communication, and regulatory issues.
Book Synopsis The COVID-19 Catastrophe by : Richard Horton
Download or read book The COVID-19 Catastrophe written by Richard Horton and published by John Wiley & Sons. This book was released on 2020-07-13 with total page 143 pages. Available in PDF, EPUB and Kindle. Book excerpt: The global response to the COVID-19 pandemic is the greatest science policy failure in a generation. We knew this was coming. Warnings about the threat of a new pandemic have been made repeatedly since the 1980s and it was clear in January that a dangerous new virus was causing a devastating human tragedy in China. And yet the world ignored the warnings. Why? In this short and hard-hitting book, Richard Horton, editor of the medical journal The Lancet, scrutinizes the actions that governments around the world took – and failed to take – as the virus spread from its origins in Wuhan to the global pandemic that it is today. He shows that many Western governments and their scientific advisors made assumptions about the virus and its lethality that turned out to be mistaken. Valuable time was lost while the virus spread unchecked, leaving health systems unprepared for the avalanche of infections that followed. Drawing on his own scientific and medical expertise, Horton outlines the measures that need to be put in place, at both national and international levels, to prevent this kind of catastrophe from happening again. Were supposed to be living in an era where human beings have become the dominant influence on the environment, but COVID-19 has revealed the fragility of our societies and the speed with which our systems can come crashing down. We need to learn the lessons of this pandemic and we need to learn them fast because the next pandemic may arrive sooner than we think.
Book Synopsis Global Trends 2040 by : National Intelligence Council
Download or read book Global Trends 2040 written by National Intelligence Council and published by Cosimo Reports. This book was released on 2021-03 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The ongoing COVID-19 pandemic marks the most significant, singular global disruption since World War II, with health, economic, political, and security implications that will ripple for years to come." -Global Trends 2040 (2021) Global Trends 2040-A More Contested World (2021), released by the US National Intelligence Council, is the latest report in its series of reports starting in 1997 about megatrends and the world's future. This report, strongly influenced by the COVID-19 pandemic, paints a bleak picture of the future and describes a contested, fragmented and turbulent world. It specifically discusses the four main trends that will shape tomorrow's world: - Demographics-by 2040, 1.4 billion people will be added mostly in Africa and South Asia. - Economics-increased government debt and concentrated economic power will escalate problems for the poor and middleclass. - Climate-a hotter world will increase water, food, and health insecurity. - Technology-the emergence of new technologies could both solve and cause problems for human life. Students of trends, policymakers, entrepreneurs, academics, journalists and anyone eager for a glimpse into the next decades, will find this report, with colored graphs, essential reading.
Book Synopsis Understanding Coronavirus by : Raul Rabadan
Download or read book Understanding Coronavirus written by Raul Rabadan and published by Cambridge University Press. This book was released on 2021-10-14 with total page 167 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since the identification of the first cases of the coronavirus in December 2019, there has been a significant amount of confusion regarding the origin and spread of the so-called 'coronavirus', SARS-CoV-2, and the cause of the disease COVID-19. Conflicting messages from the media and officials across different countries and organizations, the abundance of disparate sources of information, unfounded conspiracy theories on the origins of the virus, unproven therapies, and inconsistent public health measures, have all served to increase anxiety in the population. Where did the virus come from? How is it transmitted? How does it cause disease? Is it like flu? What is a pandemic? In this concise and accessible introduction, a leading expert provides answers to these commonly asked questions. This revised and updated edition now also covers how the virus mutates, how important these mutations are, how vaccines work, and what we can expect in the near and long-term future.
Book Synopsis Transfer Pricing and Business Restructurings by : Anuschka Bakker
Download or read book Transfer Pricing and Business Restructurings written by Anuschka Bakker and published by IBFD. This book was released on 2009 with total page 525 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book highlights the main tax issues that arise when business restructurings take place. It provides fundamental information about the drivers of business restructurings and business models, examines the application of Art. 9 of the OECD Model Convention, and considers not only the direct tax issues in business restructuring, but also VAT and customs duties. It gives practical insights into the tax accounting treatment of business restructurings, OECD work in progress and the effect of the EU tax system, and includes a case study concerning the restructuring of a manufacturing operation, which is analysed from the perspective of key industrial jurisdictions, along with an examination of current practice.
Author :National Academies of Sciences, Engineering, and Medicine Publisher :National Academies Press ISBN 13 :0309680077 Total Pages :115 pages Book Rating :4.3/5 (96 download)
Book Synopsis Reopening K-12 Schools During the COVID-19 Pandemic by : National Academies of Sciences, Engineering, and Medicine
Download or read book Reopening K-12 Schools During the COVID-19 Pandemic written by National Academies of Sciences, Engineering, and Medicine and published by National Academies Press. This book was released on 2020-11-08 with total page 115 pages. Available in PDF, EPUB and Kindle. Book excerpt: The COVID-19 pandemic has presented unprecedented challenges to the nation's K-12 education system. The rush to slow the spread of the virus led to closures of schools across the country, with little time to ensure continuity of instruction or to create a framework for deciding when and how to reopen schools. States, districts, and schools are now grappling with the complex and high-stakes questions of whether to reopen school buildings and how to operate them safely if they do reopen. These decisions need to be informed by the most up-to-date evidence about the SARS-CoV-2 virus that causes COVID-19; about the impacts of school closures on students and families; and about the complexities of operating school buildings as the pandemic persists. Reopening K-12 Schools During the COVID-19 Pandemic: Prioritizing Health, Equity, and Communities provides guidance on the reopening and operation of elementary and secondary schools for the 2020-2021 school year. The recommendations of this report are designed to help districts and schools successfully navigate the complex decisions around reopening school buildings, keeping them open, and operating them safely.
Book Synopsis Evolution of APA Regime by : Kuldeep Sharma
Download or read book Evolution of APA Regime written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-07-19 with total page 252 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.
Book Synopsis COVID-19 and Transport in Asia and the Pacific by : Asian Development Bank
Download or read book COVID-19 and Transport in Asia and the Pacific written by Asian Development Bank and published by Asian Development Bank. This book was released on 2020-12-01 with total page 102 pages. Available in PDF, EPUB and Kindle. Book excerpt: The economic and social impacts of the coronavirus disease (COVID-19) have been dramatic, and transport has played a central role in its spread. The transport sector has also enabled essential workers to get to work during the pandemic and will support the needs of the population throughout the different stages of recovery. This guidance note presents (i) the impacts of the pandemic on social and travel behaviors in Asia and the Pacific, and how the transport sector is responding; and (ii) guiding principles and good practices in transport operations to support economic recovery.
Book Synopsis COVID-19 Disinformation: A Multi-National, Whole of Society Perspective by : Ritu Gill
Download or read book COVID-19 Disinformation: A Multi-National, Whole of Society Perspective written by Ritu Gill and published by Springer Nature. This book was released on 2022-05-03 with total page 229 pages. Available in PDF, EPUB and Kindle. Book excerpt: The COVID-19 pandemic is not only a threat to our health and economy, but also has strong implications for defence and security. Indeed, defence leaders have highlighted a second fight surrounding the spread of COVID-19, namely disinformation and preparing to face adversaries willing to exploit the public health crisis for nefarious purposes. The current pandemic is a breeding ground for the propagation of disinformation, as it represents the first major global health event in which large social media platforms have become the main distributor of information. This multi-national edited volume consists of contributions from Defence Science, academia and industry, including NATO Headquarters, United States, Netherlands, Singapore, United Kingdom and Norway. The content is aimed at a diverse audience, including NATO members, researchers from defence and security organizations, academics, and militaries including analysts and practitioners, as well as policy makers. This volume focuses on various aspects of COVID-19 disinformation, including identifying global dominant disinformation narratives and the methods used to spread disinformation, examining COVID-19 disinformation within the broader context of the cognitive domain, examining the psychological effects of COVID-19 disinformation and COVID-19 disinformation on instant messaging platforms, along with examining various countermeasures to disinformation.
