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| Author | : Eduardo Baistrocchi |
| Publisher | : Cambridge University Press |
| Total Pages | : 975 |
| Release | : 2012-12-06 |
| Genre | : Law |
| ISBN | : 1139916289 |
Download Resolving Transfer Pricing Disputes Book in PDF, ePub and Kindle
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.
| Author | : Anuschka Bakker |
| Publisher | : IBFD |
| Total Pages | : 807 |
| Release | : 2011 |
| Genre | : Dispute resolution (Law). |
| ISBN | : 9087221002 |
Download Transfer Pricing and Dispute Resolution Book in PDF, ePub and Kindle
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.
| Author | : David Rosenbloom |
| Publisher | : |
| Total Pages | : |
| Release | : 2015 |
| Genre | : Dispute resolution (Law) |
| ISBN | : |
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Consists of the first three chapters of the 2011 edition which have been updated based on information available up to 15 September, 1 August, and 31 July 2014, respectively.
| Author | : S.K. Bilaney |
| Publisher | : |
| Total Pages | : |
| Release | : 2017 |
| Genre | : |
| ISBN | : |
Download Transfer Pricing Litigation Trends and Dispute Resolution Mechanisms Book in PDF, ePub and Kindle
Transfer pricing is one of the most litigious areas of taxation. This article discusses transfer pricing litigation trends in India and various dispute resolution mechanisms available to taxpayers for resolving transfer pricing disputes. In addition, analyses of statistical data relating to results achieved by various dispute resolution mechanisms are also presented.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 110 |
| Release | : 2012-01-18 |
| Genre | : |
| ISBN | : 9264169466 |
Download Dealing Effectively with the Challenges of Transfer Pricing Book in PDF, ePub and Kindle
This report addresses the practical administration of transfer pricing programmes by tax administrations.
| Author | : Zvi Daniel Altman |
| Publisher | : IBFD |
| Total Pages | : 498 |
| Release | : 2005 |
| Genre | : Arbitration and award, International |
| ISBN | : 9076078947 |
Download Dispute Resolution Under Tax Treaties Book in PDF, ePub and Kindle
As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
| Author | : G. Capristano Cardoso |
| Publisher | : |
| Total Pages | : |
| Release | : 2020 |
| Genre | : |
| ISBN | : |
Download Using Arbitration to Resolve Transfer Pricing Disputes and the Impact of the OECD's Unified Approach Proposal Book in PDF, ePub and Kindle
In this article, the author considers the use of alternative forms of dispute resolution to resolve tax treaty disputes, focusing on the potential benefits of and obstacles to using mandatory binding arbitration to resolve transfer pricing disputes, including those that may arise under the OECD's Unified Approach for allocating profits in the digital economy.
| Author | : Steven C. Wrappe |
| Publisher | : |
| Total Pages | : 0 |
| Release | : 2022 |
| Genre | : |
| ISBN | : |
Download Transfer Pricing and Transfer Pricing Disputes in the Kingdom of Saudi Arabia, Part 2 Book in PDF, ePub and Kindle
We discuss the dispute resolution procedures employed by the U.S. Internal Revenue Service (IRS) to resolve and avoid transfer pricing disputes. The IRS has enforced transfer pricing rules for decades and its experience can act as a guide for the KSA to consider the procedures to manage transfer pricing disputes. In addition, the article would help foreign investors and companies understand the KSA's tax dispute environment, especially concerning transfer pricing, and procedures to resolve or avoid transfer pricing disputes in the KSA.
| Author | : Steven C. Wrappe |
| Publisher | : |
| Total Pages | : 0 |
| Release | : 2022 |
| Genre | : |
| ISBN | : |
Download Transfer Pricing and Transfer Pricing Disputes in the Kingdom of Saudi Arabia, Part 1 Book in PDF, ePub and Kindle
As part of an increased openness to international investment and the resulting need to address international tax issues, the Kingdom of Saudi Arabia (KSA) recently adopted transfer pricing regulations consistent with global norms. Due to the newness of these regulations in the KSA tax system and the general difficulty of resolving transfer pricing disputes, the KSA continues to review the experience of other countries with transfer pricing rules, enforcement and disputes.This is the first of three papers that will examine the current and anticipated problems with the application of transfer pricing rules and explore potential methods to improve the transfer pricing dispute process in the KSA. This paper will explore the context and motivation for the adoption of transfer pricing rules by the KSA, the rules themselves, and the general enforcement approach. The second and third papers will focus on the experiences of the Internal Revenue Service (“IRS”) of the United States (“U.S.”) resolving and avoiding transfer pricing disputes and transfer pricing penalties and compliance incentives regarding transfer pricing documentation to see what procedures the KSA should consider adopting.
| Author | : David Rüll |
| Publisher | : Kluwer Law International B.V. |
| Total Pages | : 263 |
| Release | : 2024-06-10 |
| Genre | : Law |
| ISBN | : 9403520981 |
Download The Resolution of International Tax Disputes Book in PDF, ePub and Kindle
The number of international tax disputes is constantly increasing. This is a logical consequence of the pressure that is exerted on the global tax system by a rise in the number of internationally active and mobile taxpayers and tax competition between states on the one hand. On the other hand, the implementation of measures to tackle base erosion and profit shifting (BEPS) by multinational enterprises already gives rise to further disputes and another increase of disputes might arise from the latest reforms of the international tax system, namely the Two-Pillar-Solution to address the tax challenges arising from the digitalisation of the economy. Against this background, the time is right for an institutionalised international tax dispute resolution mechanism that takes into account the interests of taxpayers, states, and the public and allows for a swift and binding resolution of international tax disputes ¬– exactly what this timely and thoroughgoing book offers. A comprehensive overview of existing international tax dispute resolution mechanisms – and an analysis of their procedural rules, advantages, and disadvantages – leads to a deeply informed proposal on how they can be further developed in a way that ensures greater fairness and equity for all stakeholders. Among the lines of conflict that characterise international tax disputes, the author sheds clear light on how improvements in the design of dispute resolution mechanisms may be found. This includes these questions: How should a dispute resolution mechanism be structured? Should there be a mandatory resolution if the states cannot agree? In which way should taxpayers participate in the procedure? Should agreements and decisions be published? Should there be an institution to administer the procedure? The book concludes with a draft convention that would implement the author’s suggestions. Tax lawyers and other tax professionals worldwide, as well as national tax authorities, will benefit greatly from this book. They will deepen their understanding of the variety of existing tax dispute resolution mechanisms and discover ways to strengthen them. Academics will find ample room to reflect on the key design elements of such mechanisms and how to improve them.
