Decoding Transfer Pricing For Selling Functions

Download Decoding Transfer Pricing For Selling Functions full books in PDF, epub, and Kindle. Read online Decoding Transfer Pricing For Selling Functions ebook anywhere anytime directly on your device. Fast Download speed and no annoying ads. We cannot guarantee that every ebooks is available!

Decoding Transfer Pricing for Selling Functions

Author : Rahul K Mitra
Publisher :
ISBN 13 : 9389859743
Total Pages : 111 pages
Book Rating : 4.3/5 (898 download)

DOWNLOAD NOW!

Book Synopsis Decoding Transfer Pricing for Selling Functions by : Rahul K Mitra

Download or read book Decoding Transfer Pricing for Selling Functions written by Rahul K Mitra and published by . This book was released on 2020-08-25 with total page 111 pages. Available in PDF, EPUB and Kindle. Book excerpt: Are some of the theories of OECD and UN around marketing intangibles sacrosanct? The same have been countered through qualitative and quantitative arguments. Quantitative arguments are based upon real life scenarios, with reference to statistical analyses on selected empirical data. Genesis of litigation around marketing intangibles analysed, along with solutions. Concept of royalties for licensed manufacturers explained in the context of regulatory regime of India. Practical solutions provided on harmonisation of transfer pricing and customs duty regulations in complex cases. Concept of attribution of profits to dependent agency permanent establishments explained, with reference to Berry Ratio. Foreword by Dr. Raffalle Dr. Raffaele Petruzzi & Dr. Alfred Storck Professors of Vienna University of Economics and Business

Fundamentals of Transfer Pricing

Author : Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403535202
Total Pages : 549 pages
Book Rating : 4.4/5 (35 download)

DOWNLOAD NOW!

Book Synopsis Fundamentals of Transfer Pricing by : Raffaele Petruzzi

Download or read book Fundamentals of Transfer Pricing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2022-06-20 with total page 549 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing’s interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.

Transfer Pricing and Financing

Author : Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403540338
Total Pages : 261 pages
Book Rating : 4.4/5 (35 download)

DOWNLOAD NOW!

Book Synopsis Transfer Pricing and Financing by : Raffaele Petruzzi

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.

U.S. Transfer Pricing Sourcebook

Author : Amanda Johnson
Publisher : WorldTrade Executive, Inc.
ISBN 13 : 9781893323698
Total Pages : 124 pages
Book Rating : 4.3/5 (236 download)

DOWNLOAD NOW!

Book Synopsis U.S. Transfer Pricing Sourcebook by : Amanda Johnson

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.

Transfer Pricing and Intangibles

Author : Michael Lang
Publisher : Linde Verlag GmbH
ISBN 13 : 3709410118
Total Pages : 141 pages
Book Rating : 4.7/5 (94 download)

DOWNLOAD NOW!

Book Synopsis Transfer Pricing and Intangibles by : Michael Lang

Download or read book Transfer Pricing and Intangibles written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2019-04-11 with total page 141 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.

Fundamentals of Transfer Pricing

Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403517247
Total Pages : 484 pages
Book Rating : 4.4/5 (35 download)

DOWNLOAD NOW!

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 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.

Decoding the U.S. Corporate Tax

Author : Daniel N. Shaviro
Publisher : The Urban Insitute
ISBN 13 : 9780877667575
Total Pages : 228 pages
Book Rating : 4.6/5 (675 download)

DOWNLOAD NOW!

Book Synopsis Decoding the U.S. Corporate Tax by : Daniel N. Shaviro

Download or read book Decoding the U.S. Corporate Tax written by Daniel N. Shaviro and published by The Urban Insitute. This book was released on 2009 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The corporate tax could soon be headed in new directions," Dan Shaviro writes in Decoding the U.S. Corporate Tax, wherein he assesses the threats to America's corporate tax code and challenges conventional wisdom on the best avenues for reform. Shaviro dissects the vagaries of the law, lays out the fundamental policy issues, and considers the road ahead. As rising globalization, capital mobility, financial innovation, and political polarization combine to destabilize tax policy and government revenue, Shaviro maps the path to fair, revenue-generating reform.

Transfer Pricing in Action

Author : Aydin Hayri
Publisher : Kluwer Law International
ISBN 13 : 9789041146854
Total Pages : 0 pages
Book Rating : 4.1/5 (468 download)

DOWNLOAD NOW!

Book Synopsis Transfer Pricing in Action by : Aydin Hayri

Download or read book Transfer Pricing in Action written by Aydin Hayri and published by Kluwer Law International. This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an overview of the abstract theory of transfer pricing and its everyday practice. It is an extended hypothetical case history, presented in narrative style illustrated with graphics. It gives details of transfer pricing planning and how the process engages and affects the ambitions, insights, and interactions of the group of business people and advisors involved. The book contains the following chapters: (1) MSell - a fast growth company considers corporate taxation; (2) Big tax proposal, rejected; (3) The inevitable growing pains, and state tax planning ; (4) Going international, the Canadian expansion; (5) Further expansion: the United Kingdom and greater Europe; (6) The European distributors and a surprising development, or two; (7) Services transactions: US headquarter and support services for Europe; (8) Intangibles licensing transaction, with gusto; (9) Intra-European structuring; (10) Sourcing; (11) Branding, and a new CEO; (12) Planning for a new global business model; (13) Designing and implementing the new global business model; (14) A (rather unpleasant) Thanksgiving surprise; and a timeline figure.

Transfer Pricing Handbook

Author : Robert Feinschreiber
Publisher : John Wiley & Sons
ISBN 13 :
Total Pages : 1040 pages
Book Rating : 4.F/5 ( download)

DOWNLOAD NOW!

Book Synopsis Transfer Pricing Handbook by : Robert Feinschreiber

Download or read book Transfer Pricing Handbook written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2001 with total page 1040 pages. Available in PDF, EPUB and Kindle. Book excerpt: This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).

Practical Guide to U.S. Transfer Pricing

Author : Robert T. Cole
Publisher : Aspen Publishers
ISBN 13 :
Total Pages : 1302 pages
Book Rating : 4.0/5 ( download)

DOWNLOAD NOW!

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.

Transfer Pricing

Author : Alan Paisey
Publisher : Universal-Publishers
ISBN 13 : 1612335497
Total Pages : 152 pages
Book Rating : 4.6/5 (123 download)

DOWNLOAD NOW!

Book Synopsis Transfer Pricing by : Alan Paisey

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.

The Fundamentals of U.S. Transfer Pricing

Author : Steve C. Wrappe
Publisher :
ISBN 13 : 9781639052912
Total Pages : 0 pages
Book Rating : 4.0/5 (529 download)

DOWNLOAD NOW!

Book Synopsis The Fundamentals of U.S. Transfer Pricing by : Steve C. Wrappe

Download or read book The Fundamentals of U.S. Transfer Pricing written by Steve C. Wrappe and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Dual Transfer Pricing with Internal and External Trade

Author : Edward G. Johnson
Publisher :
ISBN 13 :
Total Pages : 33 pages
Book Rating : 4.:/5 (13 download)

DOWNLOAD NOW!

Book Synopsis Dual Transfer Pricing with Internal and External Trade by : Edward G. Johnson

Download or read book Dual Transfer Pricing with Internal and External Trade written by Edward G. Johnson and published by . This book was released on 2017 with total page 33 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines a transfer pricing problem between two divisions of a decentralized firm. The selling division is privately informed about its own costs and produces a good that is sold both externally in an intermediate market and internally within the firm. Unlike most previous work, we focus on dual transfer pricing systems that allow the selling division to be credited for an amount that differs from the amount charged to the buying division. We identify conditions under which efficient decentralized trade and external price setting incentives can be provided with a properly chosen set of dual transfer prices that do not rely on direct communication. Instead, the optimal dual transfer prices will depend only on public information about the market price charged by the upstream division in the external market, which indirectly communicates information about production costs to the downstream division. For a variety of well-known demand functions, the optimal transfer prices will be linear functions of the market price. Our main results hold when the upstream division faces multiple internal buyers or faces a binding capacity constraint.

Transfer Pricing

Author : Ralph L. Benke (Jr.)
Publisher : Institute of Management Accountants
ISBN 13 :
Total Pages : 172 pages
Book Rating : 4.4/5 (91 download)

DOWNLOAD NOW!

Book Synopsis Transfer Pricing by : Ralph L. Benke (Jr.)

Download or read book Transfer Pricing written by Ralph L. Benke (Jr.) and published by Institute of Management Accountants. This book was released on 1980 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Transfer Pricing for Multinational Enterprises

Author : H. C. Verlage
Publisher :
ISBN 13 :
Total Pages : 234 pages
Book Rating : 4.3/5 (91 download)

DOWNLOAD NOW!

Book Synopsis Transfer Pricing for Multinational Enterprises by : H. C. Verlage

Download or read book Transfer Pricing for Multinational Enterprises written by H. C. Verlage and published by . This book was released on 1975 with total page 234 pages. Available in PDF, EPUB and Kindle. Book excerpt: Monograph on transfer pricing or the pricing of products for sale between different parts of the same multinational enterprise - covers economic implications under decentralization, fiscal aspects such as customs valuation, profit taxes, etc., pricing methodology and administrative aspects. Bibliography pp. 199 to 206 and references.

The Transfer Pricing Problem

Author : Robert G. Eccles
Publisher : Free Press
ISBN 13 :
Total Pages : 376 pages
Book Rating : 4.:/5 (318 download)

DOWNLOAD NOW!

Book Synopsis The Transfer Pricing Problem by : Robert G. Eccles

Download or read book The Transfer Pricing Problem written by Robert G. Eccles and published by Free Press. This book was released on 1985 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt: Author explores the transfer pricing policies. On the beginning, he identifies the elements of administrative process that are crucial for managing the transfer pricing in corporate practice. Furthermore, he examines the management challenges of the most common transfer pricing policies. Finally, he presents general framework for strategy implementation that is designed to help managers to analyse their own company transfer pricing practices.

International Transfer Pricing

Author : Business International Corporation
Publisher :
ISBN 13 :
Total Pages : 212 pages
Book Rating : 4.:/5 (318 download)

DOWNLOAD NOW!

Book Synopsis International Transfer Pricing by : Business International Corporation

Download or read book International Transfer Pricing written by Business International Corporation and published by . This book was released on 1991 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: A comprehensive guide to corporate practices in internal control and tax compliance. Included are case studies of how firms in a variety of industries approach transfer pricing.