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Transfer Pricing The Cloud
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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.
Book Synopsis Transfer Pricing Developments Around the World 2022 by : Michael Lang
Download or read book Transfer Pricing Developments Around the World 2022 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2022-10-11 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with a far-reaching impact on countries’ legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments. Transfer Pricing Developments in the European Union. Transfer Pricing Developments in the United States. Transfer Pricing Developments in Developing Countries and Emerging Economies. Recent Developments on Transfer Pricing in the Post-Covid-19 Era. Recent Developments on Transfer Pricing and Substance. Recent Developments on Transfer Pricing and Business Restructurings. Recent Developments on Transfer Pricing and New Technologies. The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players, including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating efficient dialog and a coordinated approach to transfer pricing in the future.
Book Synopsis Transfer Pricing and Value Creation by : Raffaele Petruzzi
Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi and published by Linde Verlag GmbH. This book was released on 2019-09-02 with total page 445 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Book Synopsis Enabling the New Era of Cloud Computing: Data Security, Transfer, and Management by : Shen, Yushi
Download or read book Enabling the New Era of Cloud Computing: Data Security, Transfer, and Management written by Shen, Yushi and published by IGI Global. This book was released on 2013-11-30 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: Cloud computing is becoming the next revolution in the IT industry; providing central storage for internet data and services that have the potential to bring data transmission performance, security and privacy, data deluge, and inefficient architecture to the next level. Enabling the New Era of Cloud Computing: Data Security, Transfer, and Management discusses cloud computing as an emerging technology and its critical role in the IT industry upgrade and economic development in the future. This book is an essential resource for business decision makers, technology investors, architects and engineers, and cloud consumers interested in the cloud computing future.
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.
Book Synopsis International Taxation of Cloud Computing by : Alexander Weisser
Download or read book International Taxation of Cloud Computing written by Alexander Weisser and published by Éditions juridiques libres / Freier juristischer Verlag. This book was released on 2020-10-07 with total page 596 pages. Available in PDF, EPUB and Kindle. Book excerpt: Cloud computing may be borderless, but taxes are territorial. It is easy to imagine how the two concepts can clash. Much effort has gone into harmonizing tax rules across borders with the result that many jurisdictions have very similar tax rules. Even so, taxation remains a basic expression of national sovereignty. The goal of this thesis is to examine how international tax law applies to the cross-border cloud computing business. Both, multinational providers and customers of cloud computing services are analyzed. Reflecting three traditional areas of international tax scholarship, the goal could be stated in three questions. Which jurisdictions have the right to tax? What kinds of cloud computing transactions can be taxed? What amount of the profit is taxable? In more technical terms, this means enquiring into how the use of cloud computing affects the permanent establishment status of taxpayers, how the different kinds of cloud computing transactions are characterized under international double taxation treaties, and how the calculation of taxable cloud computing profit is affected by transfer pricing. In light of the current political events, the thesis also offers recommendations de lege lata through a systematic approach. Its first part assesses the current taxation of cloud computing. The second part evaluates whether the findings of this initial assessment conform to various superior principles of good rulemaking. It identifies which of the present tax rules ought to be adapted. The final part considers how the rules could be amended to become more compliant with the superior principles. In this way, Part I embodies the thesis, Part II the antithesis, and Part III seeks a synthesis.
Book Synopsis Tax Transfer Pricing by : Andrea Musselli
Download or read book Tax Transfer Pricing written by Andrea Musselli and published by Gruppo 24 Ore. This book was released on 2022-09-15T00:00:00+02:00 with total page 446 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.
Book Synopsis The Dialectical Path of Law by : Charles Lincoln
Download or read book The Dialectical Path of Law written by Charles Lincoln and published by Rowman & Littlefield. This book was released on 2021-10-13 with total page 285 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book aims to contribute a single idea – a new way to interpret legal decisions in any field of law and in any capacity of interpreting law through a theory called legal dialects. This theory of the dialectical path of law uses the Hegelian dialectic which compares and contrasts two ideas, showing how they are concurrently the same but separate, without the original ideas losing their inherent and distinctive properties – what in Hegelian terms is referred to as the sublation. To demonstrate this theory, Lincoln takes different aspects of international tax law and corporate law, two fields that seem entirely contradictory, and shows how they are similar without disregarding their key theoretical properties. Primarily focusing on the technical rules of the Organisation for Economic Co-operation and Development (OECD) approach to international tax law and the United States approach to tax law, Lincoln shows that both engage in the Hegelian dialectical approach to law.
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.
Book Synopsis Tax and Technology by : Annika Streicher
Download or read book Tax and Technology written by Annika Streicher and published by Linde Verlag GmbH. This book was released on 2023-10-13 with total page 683 pages. Available in PDF, EPUB and Kindle. Book excerpt: The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, indirect tax law, and tax procedures including tax compliance, and tax control functions. International organizations such as the Organization for Economic Co-operation and Development (OECD), the United Nations (UN), and the European Commission as a supranational organization fostered critical legislative reforms and proposals among which are the OECD Two-Pillar Solution to Address the Tax Challenges Arising from Digitalisation of the Economy, Article 12B of the UN Model Tax Convention to tax automated digital services, new rules for tracing transfers of crypto-assets in the EU, as well as the EU ́s VAT e-commerce package and "VAT in the Digital Age" package. While these proposals aim to address a wide range of the benefits and challenges of Economy 4.0, certain questions arise concerning the consistency of the legislative developments with their initial objectives, the appropriateness of the legal form for the economic substance of the regulated relations for the effectiveness of the regulations as well as their coherence. This volume contains a collection of scientific chapters on the general topic "Tax and Technology" that were successfully completed by the 2022/2023 LL.M. graduates of the Institute for Austrian and International Tax Law, WU. The volume is divided into three parts that contain the contributions dealing with the impact of the technology on international tax law, indirect tax law, and procedural law. Each chapter provides an in-depth analysis of a unique research question aiming to innovatively contribute to the current debate and develop a practical approach for implementing the findings.
Book Synopsis Ambient Communications and Computer Systems by : Yu-Chen Hu
Download or read book Ambient Communications and Computer Systems written by Yu-Chen Hu and published by Springer Nature. This book was released on 2022-05-07 with total page 620 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book features high-quality, peer-reviewed papers from the Fourth International Conference on Recent Advancements in Computer, Communication, and Computational Sciences (RACCCS 2021), held at Aryabhatta College of Engineering and Research Center, Ajmer, India, on August 20–21, 2021. Presenting the latest developments and technical solutions in computational sciences, it covers a variety of topics, such as intelligent hardware and software design, advanced communications, intelligent computing technologies, advanced software engineering, the web and informatics, and intelligent image processing. As such, it helps those in the computer industry and academia to use the advances in next-generation communication and computational technology to shape real-world applications.
Book Synopsis Advances in Grid and Pervasive Computing by : Ruixuan Li
Download or read book Advances in Grid and Pervasive Computing written by Ruixuan Li and published by Springer. This book was released on 2012-05-08 with total page 389 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book constitutes the refereed proceedings of the 7th International Conference on Grid and Pervasive Computing, GPC 2012, held in Hong Kong, China, in May 2012. The 9 revised full papers and 19 short papers were carefully revised and selected from 55 submissions. They are organized in topical sections on cloud computing, grid and service computing, green computing, mobile and pervasive computing, scheduling and performance, and trust and security. Also included are 4 papers presented at the 2012 International Workshop on Mobile Cloud and Ubiquitous Computing (Mobi-Cloud 2012) held in conjunction with GPC 2012.
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.
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.
Download or read book Federal Tax Articles written by and published by . This book was released on 1992 with total page 1874 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Cloud Computing by : Jared Carstensen
Download or read book Cloud Computing written by Jared Carstensen and published by IT Governance Ltd. This book was released on 2012-04-17 with total page 297 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book will enable you to: understand the different types of Cloud and know which is the right one for your business have realistic expectations of what a Cloud service can give you, and enable you to manage it in the way that suits your business minimise potential disruption by successfully managing the risks and threats make appropriate changes to your business in order to seize opportunities offered by Cloud set up an effective governance system and benefit from the consequential cost savings and reductions in expenditure understand the legal implications of international data protection and privacy laws, and protect your business against falling foul of such laws know how Cloud can benefit your business continuity and disaster recovery planning.
Book Synopsis Microsoft Azure Pricing & Support Options by : Richie Miller
Download or read book Microsoft Azure Pricing & Support Options written by Richie Miller and published by Richie Miller. This book was released on with total page 66 pages. Available in PDF, EPUB and Kindle. Book excerpt: If you want to PASS the MICROSOFT AZURE AZ-900 EXAM, this book is for you! BUY THIS BOOK NOW AND GET STARTED TODAY! The AZ-900 Exam centres on the knowledge required to define cloud service benefits and usage considerations; explain IaaS, PaaS, and SaaS; compare public, private, and hybrid cloud models; describe core Azure architectural components, products, solutions, and management tools; describe how network connectivity is secured in Azure; describe core identity services; describe Azure security tools, features, governance methodologies, and monitoring and reporting options; describe privacy, compliance, and data protection standards; describe Azure subscriptions, cost planning, and cost management; and describe SLAs and the service lifecycle. In this book you will discover: · Introduction to Azure Subscriptions · How to create an Azure Subscription · How to Add and Name Azure Subscriptions · How to Provision a New Azure Subscription · Azure Management Groups · Azure Planning & Management Costs · Azure Free Subscription & Free Services Options · What’s Affecting Azure Costs? · Best Practices for Minimizing Azure Costs · Azure Pricing Calculator Basics · How to use the Azure Price Calculator · Azure Support Options · Azure Knowledge Center · How to open a Support Ticket on Azure Knowledge Center · Azure Service Level Agreements · How to Determine the Appropriate SLA · Azure Service Lifecycle BUY THIS BOOK NOW AND GET STARTED TODAY!
