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The Transfer Pricing Problem And The Multinational Firm
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Book Synopsis International Transfer Pricing Policies by : Wagdy M. Abdallah
Download or read book International Transfer Pricing Policies written by Wagdy M. Abdallah and published by Praeger. This book was released on 1989-03-13 with total page 184 pages. Available in PDF, EPUB and Kindle. Book excerpt: "In this valuable work Professor Abdallah lays out the factors a good international transfer pricing system should have. . . . A multinational enterprise must reach a number of business decisions involving transfer pricing, such as where to manufacture a specific product, levels of capital investment, and profit planning by location. Rather than shooting from the hip' and trying to solve problems one at a time, Professor Abdallah says, companies should develop a comprehensive policy to resolve the inevitable problems. In short, transfer pricing problems are here and will continue to be here. While there is no single answer, a written policy approach is best. Anyone responsible for international transfer pricing will be helped immeasurably by referring to this valuable book." Management Accounting
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.
Book Synopsis Multinationals and Transfer Pricing by : Alan M. Rugman
Download or read book Multinationals and Transfer Pricing written by Alan M. Rugman and published by Routledge. This book was released on 2017-02-03 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: One of the reasons for the success of multinational enterprises in their ability to create in their supranational organisations "internal markets" which eliminate the imperfections of external world markets caused by tariffs on trade, restrictions on the flow of capital, information costs and so on. The method multinationals use to create and sustain internal markets is transfer pricing. Multinationals use to their advantage the difference between nominal accounting and real transfers from their head offices to a subsidiary in different countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals’ use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.
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.
Book Synopsis Transfer Pricing in International Business by : Geoff Turner
Download or read book Transfer Pricing in International Business written by Geoff Turner and published by Business Expert Press. This book was released on 2013-03-15 with total page 114 pages. Available in PDF, EPUB and Kindle. Book excerpt: For centuries, trade has endured stumbling blocks, mistakes, and moments of inspiration. It has contributed to the modern, globalized world in which we live, and the increasing economic, social, and political importance of trade has spawned a phenomenon called the multinational organization. However, these organizations have a national home to where profits will ultimately have to come, and in their effort to maximize the amount repatriated, they often engage in internal-pricing practices, known more commonly as transfer pricing This book reminds us all of the important issues of transfer pricing, and how easy it is to create friction between all of the interested parties. This book also goes on to provide an insight into how such conflicts can be assuaged or avoided altogether, and explains how transfer pricing may become a managerial tool by establishing a common language that may be used as one driver for creating added value throughout the organization. Transfer pricing is not simply about maximizing income. It is a much more important strategic management issue that, treated unwisely or with ignorance, is likely to lead to an incongruity in the added value of an organization’s products and services as well as its crucial return on capital employed.
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.
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.
Book Synopsis Taxes and Business Strategy by : Myron S. Scholes
Download or read book Taxes and Business Strategy written by Myron S. Scholes and published by . This book was released on 2015-01-03 with total page 528 pages. Available in PDF, EPUB and Kindle. Book excerpt: For MBA students and graduates embarking on careers in investment banking, corporate finance, strategy consulting, money management, or venture capital Through integration with traditional MBA topics, Taxes and Business Strategy, Fifth Edition provides a framework for understanding how taxes affect decision-making, asset prices, equilibrium returns, and the financial and operational structure of firms. Teaching and Learning Experience This program presents a better teaching and learning experience-for you and your students: *Use a text from an active author team: All 5 authors actively teach the tax and business strategy course and provide students with relevant examples from both classroom and real-world consulting experience. *Teach students the practical uses for business strategy: Students learn important concepts that can be applied to their own lives. *Reinforce learning by using in-depth analysis: Analysis and explanatory material help students understand, think about, and retain information.
Book Synopsis Transfer Pricing Aspects of Intra-Group Financing by : Raffaele Petruzzi
Download or read book Transfer Pricing Aspects of Intra-Group Financing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2013-10-20 with total page 286 pages. Available in PDF, EPUB and Kindle. Book excerpt: For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.
Book Synopsis Transfer Pricing in the 1990s by : Roger Y. Tang
Download or read book Transfer Pricing in the 1990s written by Roger Y. Tang and published by Praeger. This book was released on 1993-01-30 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt: The author discusses changes in transfer pricing regulations introduced by the U.S. government and its major trading partners, and gives information (obtained from a survey done in 1990) on U.S. transfer pricing practices, comparing them with those of an earlier study done in 1977.
Book Synopsis Transfer Pricing and Corporate Taxation by : Elizabeth King
Download or read book Transfer Pricing and Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2008-10-11 with total page 199 pages. Available in PDF, EPUB and Kindle. Book excerpt: National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.
Book Synopsis Transfer Pricing Answer Book by : David B. Blair
Download or read book Transfer Pricing Answer Book written by David B. Blair and published by . This book was released on 2017-05-07 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The phenomena of increasingly global business enterprises with valuable intangible property expose companies to transfer pricing enforcement by different countries around the world. Many of these countries are increasingly aggressive in enforcing their local transfer pricing rules, as they attempt to protect their tax revenue base. To avoid double taxation of the same income in this environment, companies often are required to deal with the highly specialized, bilateral treaty-based competent authority process developed to prevent double taxation at a time when trade mainly involved only two established countries. Even more challenging today, companies and tax authorities increasingly are faced with the potential for multiple taxation of the same income, as supply chains cross many borders and as the tax authorities of emerging countries become players in the global taxation process, and the resulting stresses, strains, and limitations of the bilateral treaty-based competent authority process have become more apparent. In light of the high-dollar risks presented by the increased enforcement efforts of tax authorities worldwide, the complexity of the ever-changing, inherently uncertain transfer pricing standards, and the continually evolving business models of businesses adapting to the constantly changing global economy, companies need practical guidance to permit them to develop and defend their transfer pricing strategies. Transfer Pricing Answer Book gives companies such guidance by discussing all aspects of transfer pricing, from initially planning a transfer pricing strategy, to alternative ways to defend the strategy from attack by two or more tax authorities, to resolving a case before competent authorities, to bringing a transfer pricing case to court. The book's non-technical discussion is presented in a question and answer format that will appeal to readers regardless of their prior level of experience or familiarity with taxes in general and transfer pricing in particular. Transfer Pricing Answer Book is an invaluable resource for company executives and their advisors who are seeking to better understand this important area of tax law that has become such an important economic facet of so many businesses.
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.
Book Synopsis Transfer Pricing and Developing Economies by : Joel Cooper
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.
Book Synopsis Transfer Pricing and the Arm's Length Principle in International Tax Law by : Jens Wittendorff
Download or read book Transfer Pricing and the Arm's Length Principle in International Tax Law written by Jens Wittendorff and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 914 pages. Available in PDF, EPUB and Kindle. Book excerpt: The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.
Book Synopsis Readings in Accounting for Management Control by : David Otley and Kenneth Merchant Clive Emmanuel
Download or read book Readings in Accounting for Management Control written by David Otley and Kenneth Merchant Clive Emmanuel and published by Springer. This book was released on 2013-12-19 with total page 689 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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.
