Critical Concerns In Transfer Pricing And Practice

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Critical Concerns in Transfer Pricing and Practice

Author : Wagdy M. Abdallah
Publisher : Bloomsbury Publishing USA
ISBN 13 : 0313053685
Total Pages : 272 pages
Book Rating : 4.3/5 (13 download)

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Book Synopsis Critical Concerns in Transfer Pricing and Practice by : Wagdy M. Abdallah

Download or read book Critical Concerns in Transfer Pricing and Practice written by Wagdy M. Abdallah and published by Bloomsbury Publishing USA. This book was released on 2004-07-30 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: For multinational corporations (MNCs), there is arguably no more important operational function that affects all areas of manufacturing, marketing, management, and finance as international transfer pricing—the practicing of supplying products or services across borders from one part of the organization to another. Its complexity is compounded by the impact of e-commerce, speeding the flow of goods and services; intangible assets, such as intellectual property, whose value is difficult to quantify; and the activites of policymakers around the world to update their tax laws and regulations, in efforts to close loopholes that have historically encouraged tax avoidance. In Critical Concerns in Transfer Pricing Policy and Practice, Wagdy Abdallah provides an in-depth overview of these recent trends and developments, and considers their implications for the management of MNCs. In particular, he discusses methods for pricing transferred goods and services in the e-commerce era and analyzes the most recent regulation reforms in such countries as Germany, Mexico, Japan, Canada, the United Kingdom, the United States, and the Netherlands. Anticipating increased scrutiny of MNC transfer pricing practices from governments and other external stakeholders, Abdallah outlines a set of practical recommendations for creating a successful transfer pricing system that maximizes value for the company while remaining sensitive to local policies in all of the countries in which it operates.

Dealing Effectively with the Challenges of Transfer Pricing

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264169466
Total Pages : 110 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Dealing Effectively with the Challenges of Transfer Pricing by : OECD

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.

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.

International Transfer Pricing in Asia Pacific

Author : J. Li
Publisher : Springer
ISBN 13 : 0230511600
Total Pages : 296 pages
Book Rating : 4.2/5 (35 download)

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Book Synopsis International Transfer Pricing in Asia Pacific by : J. Li

Download or read book International Transfer Pricing in Asia Pacific written by J. Li and published by Springer. This book was released on 2005-09-08 with total page 296 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the management of business activity by companies operating in more than one country, the complex array of issues and practices that characterize their movements of assets between constituent company units centres around what has become known as international transfer payments. This book, based on extensive research, explains the nature of the subject, presents the latest data on the practice of transfer payments in three Asia Pacific countries; the regulations, attitudes and conditions which form the context in which they take place; and the events which are most likely to precipitate the intervention of the authorities and lead to investigation and audit.

Taxing Multinationals

Author : Lorraine Eden
Publisher : University of Toronto Press
ISBN 13 : 9780802007766
Total Pages : 788 pages
Book Rating : 4.0/5 (77 download)

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Book Synopsis Taxing Multinationals by : Lorraine Eden

Download or read book Taxing Multinationals written by Lorraine Eden and published by University of Toronto Press. This book was released on 1998-01-01 with total page 788 pages. Available in PDF, EPUB and Kindle. Book excerpt: Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.

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.

Transfer Pricing and Dispute Resolution

Author : Anuschka Bakker
Publisher : IBFD
ISBN 13 : 9087221002
Total Pages : 807 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Transfer Pricing and Dispute Resolution by : Anuschka Bakker

Download or read book Transfer Pricing and Dispute Resolution written by Anuschka Bakker and published by IBFD. This book was released on 2011 with total page 807 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.

Accounting for Non-accountants

Author : Graham Mott
Publisher : Kogan Page Publishers
ISBN 13 : 0749452641
Total Pages : 368 pages
Book Rating : 4.7/5 (494 download)

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Book Synopsis Accounting for Non-accountants by : Graham Mott

Download or read book Accounting for Non-accountants written by Graham Mott and published by Kogan Page Publishers. This book was released on 2008 with total page 368 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Provides the perfect introduction to the basics of accounting and business finance. It takes you through accounting and financial techniques and terms in an easy-to-follow style."--Cover.

Delivering Results

Author : Lawrence P. Carr
Publisher : Springer Science & Business Media
ISBN 13 : 1441906215
Total Pages : 213 pages
Book Rating : 4.4/5 (419 download)

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Book Synopsis Delivering Results by : Lawrence P. Carr

Download or read book Delivering Results written by Lawrence P. Carr and published by Springer Science & Business Media. This book was released on 2009-07-28 with total page 213 pages. Available in PDF, EPUB and Kindle. Book excerpt: For any organization to perform and compete successfully, it must have the systems and processes in place to translate goals into achievable actions—and to measure and monitor results. Moreover, the organization must be able to adjust and adapt as market conditions, technologies, the competitive environment, government regulations, personnel, and other variables evolve, sometimes gradually and sometimes dramatically. In Delivering Results: Measuring What Matters, Babson College professors and management consultants, Lawrence Carr and Alfred Nanni, show managers how to avoid the common pitfalls and mistakes when setting corporate strategy, and instead create a management system—unique to their organization—that aligns internal resources with objectives, motivates and rewards employees, and continuously provides feedback. Illustrating their concepts with numerous real-life examples (both successes and failures), practical tools and models, and a glossary of key terms, the authors demonstrate that knowing how to create and direct management systems that deliver results is, in itself, a strategic resource.

Transfer Pricing Methods

Author : Robert Feinschreiber
Publisher : John Wiley & Sons
ISBN 13 : 0471651230
Total Pages : 338 pages
Book Rating : 4.4/5 (716 download)

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Book Synopsis Transfer Pricing Methods by : Robert Feinschreiber

Download or read book Transfer Pricing Methods written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2004-03-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advanced praise for Transfer Pricing Methods "Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue." -Charles R. Goulding, Managing Director, Tax Cooper Industries, Inc. "It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses." -Vikram A. Gosain, JD, CPA, Director of Transfer Pricing General Electric Capital Corporation "This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants." -Joseph C. Mandarino, Partner Troutman Sanders, LLP "Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty." -Charles L. Crowley, Partner ITS/Customs and International Trade Practice, Ernst & Young, LLP "Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational." -Enrique MacGregor, Principal-in-Charge, Transfer Pricing Services Grant Thornton LLP "Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate." -Alan Getz, Vice President and General Manager, Tax Mitsui & Co., Inc. (U.S.A.) "Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner." -Per H. Hasenwinkle, National Practice Leader, Transfer Pricing BDO Seidman, LLP

International Business Finance

Author : Michael Connolly
Publisher : Routledge
ISBN 13 : 1135991774
Total Pages : 278 pages
Book Rating : 4.1/5 (359 download)

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Book Synopsis International Business Finance by : Michael Connolly

Download or read book International Business Finance written by Michael Connolly and published by Routledge. This book was released on 2006-11-28 with total page 278 pages. Available in PDF, EPUB and Kindle. Book excerpt: This textbook introduces students to the fundamental workings of business and finance in the global economy. It brings clarity and focus to the complexities of the field and demonstrates the key linkages between the foreign exchange markets and world money markets. Core topics examined include: corporate aspects of international finance, with special attention given to contractual and operational hedging techniques the mechanics of the foreign exchange markets the building blocks of international finance the optimal portfolio in an international setting. Michael Connolly also provides up-to-date statistics from across the globe, relevant international case studies, problem sets and solutions and links to an online PowerPoint presentation. International Business Finance is an engaging and stimulating text for students in undergraduate and MBA courses in international finance and a key resource for lecturers.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264265120
Total Pages : 612 pages
Book Rating : 4.2/5 (642 download)

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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 612 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.

Fundamentals of International Transfer Pricing in Law and Economics

Author : Wolfgang Schön
Publisher : Springer Science & Business Media
ISBN 13 : 3642259804
Total Pages : 308 pages
Book Rating : 4.6/5 (422 download)

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Book Synopsis Fundamentals of International Transfer Pricing in Law and Economics by : Wolfgang Schön

Download or read book Fundamentals of International Transfer Pricing in Law and Economics written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2012-02-15 with total page 308 pages. Available in PDF, EPUB and Kindle. Book excerpt: The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.

Model Rules of Professional Conduct

Author : American Bar Association. House of Delegates
Publisher : American Bar Association
ISBN 13 : 9781590318737
Total Pages : 216 pages
Book Rating : 4.3/5 (187 download)

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Book Synopsis Model Rules of Professional Conduct by : American Bar Association. House of Delegates

Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264921915
Total Pages : 658 pages
Book Rating : 4.2/5 (649 download)

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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 658 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.

Uniform Issue List

Author :
Publisher :
ISBN 13 :
Total Pages : 84 pages
Book Rating : 4.:/5 (31 download)

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Book Synopsis Uniform Issue List by :

Download or read book Uniform Issue List written by and published by . This book was released on 1986 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:

United Nations Practical Manual on Transfer Pricing for Developing Countries 2017

Author : United Nations
Publisher :
ISBN 13 :
Total Pages : 672 pages
Book Rating : 4.:/5 (31 download)

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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.