Transfer Pricing Disputes In The Manufacturing Industry

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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.

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.

Transfer Pricing in Manufacturing

Author : Ioana Ignat
Publisher : Springer Nature
ISBN 13 : 3030938891
Total Pages : 196 pages
Book Rating : 4.0/5 (39 download)

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Book Synopsis Transfer Pricing in Manufacturing by : Ioana Ignat

Download or read book Transfer Pricing in Manufacturing written by Ioana Ignat and published by Springer Nature. This book was released on 2022-05-09 with total page 196 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is considered a new and complex concept in terms of guidelines and regulations. In this context, more and more academics and tax professionals are interested in understanding the mechanism of a transfer pricing analysis. The main objective of the book is to help them in this process by presenting in a practical approach (using case studies and schemes) and in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations the way in which are operating the basic transfer pricing elements. Moreover, considering that the manufacturing sector is the chief wealth-producing sector of the global economy, the book illustrates complete transfer pricing analyses applicable for manufacturing transactions (using Orbis database). In the end, the book presents some recent disputes between manufacturing entities and tax authorities in relation to the transfer pricing analysis for manufacturing transactions. Chapter “TAMSAT” is available open access under a Creative Commons Attribution 4.0 International License via link.springer.com.

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.

Transfer Pricing Answer Book

Author : David B. Blair
Publisher :
ISBN 13 : 9781402428456
Total Pages : 0 pages
Book Rating : 4.4/5 (284 download)

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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.

Resolving Transfer Pricing Disputes

Author : Eduardo Baistrocchi
Publisher : Cambridge University Press
ISBN 13 : 1139916289
Total Pages : 975 pages
Book Rating : 4.1/5 (399 download)

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Book Synopsis Resolving Transfer Pricing Disputes by : Eduardo Baistrocchi

Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

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)

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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.

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.

Multinationals and Transfer Pricing

Author : Alan M. Rugman
Publisher : Routledge
ISBN 13 : 1351999680
Total Pages : 292 pages
Book Rating : 4.3/5 (519 download)

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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.

International Transfer Pricing

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

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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.

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.

Addressing Base Erosion and Profit Shifting

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264192743
Total Pages : 91 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Addressing Base Erosion and Profit Shifting by : OECD

Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

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.

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

Fiscal Regimes for Extractive Industries—Design and Implementation

Author : International Monetary Fund. Fiscal Affairs Dept.
Publisher : International Monetary Fund
ISBN 13 : 1498340067
Total Pages : 82 pages
Book Rating : 4.4/5 (983 download)

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Book Synopsis Fiscal Regimes for Extractive Industries—Design and Implementation by : International Monetary Fund. Fiscal Affairs Dept.

Download or read book Fiscal Regimes for Extractive Industries—Design and Implementation written by International Monetary Fund. Fiscal Affairs Dept. and published by International Monetary Fund. This book was released on 2012-08-16 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación

Ask a Manager

Author : Alison Green
Publisher : Ballantine Books
ISBN 13 : 0399181822
Total Pages : 306 pages
Book Rating : 4.3/5 (991 download)

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Book Synopsis Ask a Manager by : Alison Green

Download or read book Ask a Manager written by Alison Green and published by Ballantine Books. This book was released on 2018-05-01 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: From the creator of the popular website Ask a Manager and New York’s work-advice columnist comes a witty, practical guide to 200 difficult professional conversations—featuring all-new advice! There’s a reason Alison Green has been called “the Dear Abby of the work world.” Ten years as a workplace-advice columnist have taught her that people avoid awkward conversations in the office because they simply don’t know what to say. Thankfully, Green does—and in this incredibly helpful book, she tackles the tough discussions you may need to have during your career. You’ll learn what to say when • coworkers push their work on you—then take credit for it • you accidentally trash-talk someone in an email then hit “reply all” • you’re being micromanaged—or not being managed at all • you catch a colleague in a lie • your boss seems unhappy with your work • your cubemate’s loud speakerphone is making you homicidal • you got drunk at the holiday party Praise for Ask a Manager “A must-read for anyone who works . . . [Alison Green’s] advice boils down to the idea that you should be professional (even when others are not) and that communicating in a straightforward manner with candor and kindness will get you far, no matter where you work.”—Booklist (starred review) “The author’s friendly, warm, no-nonsense writing is a pleasure to read, and her advice can be widely applied to relationships in all areas of readers’ lives. Ideal for anyone new to the job market or new to management, or anyone hoping to improve their work experience.”—Library Journal (starred review) “I am a huge fan of Alison Green’s Ask a Manager column. This book is even better. It teaches us how to deal with many of the most vexing big and little problems in our workplaces—and to do so with grace, confidence, and a sense of humor.”—Robert Sutton, Stanford professor and author of The No Asshole Rule and The Asshole Survival Guide “Ask a Manager is the ultimate playbook for navigating the traditional workforce in a diplomatic but firm way.”—Erin Lowry, author of Broke Millennial: Stop Scraping By and Get Your Financial Life Together

Patterns of Technological Innovation

Author : Devendra Sahal
Publisher : Addison Wesley Longman
ISBN 13 :
Total Pages : 408 pages
Book Rating : 4.3/5 (91 download)

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Book Synopsis Patterns of Technological Innovation by : Devendra Sahal

Download or read book Patterns of Technological Innovation written by Devendra Sahal and published by Addison Wesley Longman. This book was released on 1981 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Monograph on causes, trends and impact of technological change - presents definitions and theoretical approaches to the description of the origin, diffusion and development of new technology (incl. Historical inventions and innovations), discusses effects on long term economic growth, manufacturing, learning, research and development, etc., and includes science policy, educational policy and industrial policy suggestions and case studies. Graphs and references.