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Transfer Pricing and Valuation in Corporate Taxation

Transfer Pricing and Valuation in Corporate Taxation
Author: Elizabeth King
Publisher: Springer Science & Business Media
Total Pages: 294
Release: 2007-05-08
Genre: Law
ISBN: 0306482185
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Transfer Pricing and Valuation in Corporate Taxation analyzes the disparities between both federal statutes and regulations, and r- ulations and administrative practice, in a highly controversial area of corporate tax policy: intra-company transfer pricing for tax p- poses. It addresses issues that often mean millions of dollars to in- vidual corporations, and a significant fraction of the federal gove- ment’s revenue base. These disparities between law, regulations, and administrative practice are concerning on a number of grounds. First, they - pose considerable economic costs by inducing corporations to engage in a variety of “rent-seeking” activities designed to reduce their - pected tax liabilities, and by requiring the IRS to devote still more to enforcement efforts that are very often futile. Second, they are in- ; herently undemocratic. Administrative practice is currently ad hoc by relying on dispute resolution procedures that can and do yield very different settlements on disputed tax issues from one case to another, the IRS often ends up treating similarly situated cor- rations very differently. Moreover, to the extent that the disp- ity between statute and implementation reflects the IRS’s failure to carry out Congress’ will, the laws passed by duly elected officials are effectively being superseded by administrative procedure, developed incrementally by individuals who are not answerable to an electorate.

Transfer Pricing and Corporate Taxation

Transfer Pricing and Corporate Taxation
Author: Elizabeth King
Publisher: Springer Science & Business Media
Total Pages: 199
Release: 2008-10-11
Genre: Business & Economics
ISBN: 0387781838
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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.

Transfer Pricing and Customs Valuation

Transfer Pricing and Customs Valuation
Author: Anuschka Bakker
Publisher: IBFD
Total Pages: 695
Release: 2009
Genre: Customs appraisal
ISBN: 9087220596
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This book discusses the intricate role of transfer pricing and customs value in international business environment. It examines the relationship between valuation for transfer pricing purposes and valuation for customs, and the significance of the relationship for multinational enterprises, tax authorities and customs administrations. The book begins by reviewing relevant international standards such as the OECD Guidelines and the GATT/WTO Customs Valuation Agreement. This is followed by a discussion of related issues such as VAT and administrative matters. Country chapters provide an overview of the applicable legislation and valuation methods, and case studies allow direct comparison between the practices of the different countries. The book concludes by summarizing the existing relationship between transfer pricing valuations and customs valuations, and by suggesting possible solutions towards a more integrated approach.

Business Valuation and Federal Taxes

Business Valuation and Federal Taxes
Author: David Laro
Publisher: John Wiley & Sons
Total Pages: 532
Release: 2011-05-03
Genre: Business & Economics
ISBN: 0470601620
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Business Valuation and Federal Taxes Procedure, Law, and Perspective SECOND EDITION Combining the expert knowledge of Senior Judge David Laro and Shannon Pratt, Business Valuation and Federal Taxes, Second Edition presents the authors' decades of experience, with advice on everything practitioners need to know about the relationship between federal taxes and valuation, and specifically valuations relating to business interests. This reference features indepth examinations of numerous topics that are particularly important to practitioners and explores a broad understanding of the basic knowledge needed to appreciate business valuation. Valuators, CPAs consulting on valuations, attorneys, corporate development officers, and intermediaries on business valuation will benefit from insightful discussions on topics ranging from general definitions to valuing complex business interests, as well as new discussions of: Personal versus enterprise goodwill New materials on transfer pricing and customs valuations and how recent markets have affected both the income and market approaches Coverage of FAS 157 and the many changes to penalties and sanctions affecting both taxpayers and appraisers Several important new court cases Coverage is also included on standards of business valuation, IRS positions, burden of proof in valuation controversies, questions to ask business valuation experts, economic and industry analysis, and tax-affecting passthrough entities. Complete with a full overview of the laws, procedures, and approaches related to business valuation, this invaluable reference is a wellspring of vital information on valuation approaches, techniques, finance-related issues, burden of proof, standards, choice of entity, and much more.

Transfer Pricing and Intangibles

Transfer Pricing and Intangibles
Author: Michael Lang
Publisher: Linde Verlag GmbH
Total Pages: 176
Release: 2019-04-11
Genre: Law
ISBN: 370941010X
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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.

Transfer Pricing and Business Restructurings

Transfer Pricing and Business Restructurings
Author: Anuschka Bakker
Publisher: IBFD
Total Pages: 525
Release: 2009
Genre: Corporate reorganizations
ISBN: 9087220553
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This book highlights the main tax issues that arise when business restructurings take place. It provides fundamental information about the drivers of business restructurings and business models, examines the application of Art. 9 of the OECD Model Convention, and considers not only the direct tax issues in business restructuring, but also VAT and customs duties. It gives practical insights into the tax accounting treatment of business restructurings, OECD work in progress and the effect of the EU tax system, and includes a case study concerning the restructuring of a manufacturing operation, which is analysed from the perspective of key industrial jurisdictions, along with an examination of current practice.

Guide to International Transfer Pricing

Guide to International Transfer Pricing
Author: Dr A. Michael Heimert
Publisher: Kluwer Law International B.V.
Total Pages: 1290
Release: 2018-10-26
Genre: Law
ISBN: 9403501715
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The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.

Transfer Pricing

Transfer Pricing
Author: Fouad Sabry
Publisher: One Billion Knowledgeable
Total Pages: 304
Release: 2024-03-28
Genre: Business & Economics
ISBN:
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What is Transfer Pricing Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm's length. The OECD and World Bank recommend intragroup pricing rules based on the arm's-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative practice. Countries with transfer pricing legislation generally follow the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in most respects, although their rules can differ on some important details. How you will benefit (I) Insights, and validations about the following topics: Chapter 1: Transfer pricing Chapter 2: Tax deduction Chapter 3: Capital gain Chapter 4: Tax treaty Chapter 5: Corporate tax Chapter 6: Indirect tax Chapter 7: Partnership taxation in the United States Chapter 8: Arm's length principle Chapter 9: Gross income Chapter 10: International taxation Chapter 11: Tax consolidation Chapter 12: Patent valuation Chapter 13: Optimal tax Chapter 14: Advance pricing agreement Chapter 15: Corporate tax in the United States Chapter 16: Foreign tax credit Chapter 17: Transactional net margin method Chapter 18: Transfer mispricing Chapter 19: Canada v GlaxoSmithKline Inc Chapter 20: Base erosion and profit shifting Chapter 21: Base erosion and profit shifting (OECD project) (II) Answering the public top questions about transfer pricing. (III) Real world examples for the usage of transfer pricing in many fields. Who this book is for Professionals, undergraduate and graduate students, enthusiasts, hobbyists, and those who want to go beyond basic knowledge or information for any kind of Transfer Pricing.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017
Author: OECD
Publisher: OECD Publishing
Total Pages: 612
Release: 2017-07-10
Genre:
ISBN: 9264265120
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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.