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| Author | : Geoff Turner |
| Publisher | : Business Expert Press |
| Total Pages | : 114 |
| Release | : 2013-03-15 |
| Genre | : Business & Economics |
| ISBN | : 1606493493 |
Download Transfer Pricing in International Business Book in PDF, ePub and Kindle
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.
| Author | : Wolfgang Schön |
| Publisher | : Springer Science & Business Media |
| Total Pages | : 308 |
| Release | : 2012-02-15 |
| Genre | : Law |
| ISBN | : 3642259804 |
Download Fundamentals of International Transfer Pricing in Law and Economics Book in PDF, ePub and Kindle
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.
| Author | : David B. Blair |
| Publisher | : |
| Total Pages | : 0 |
| Release | : 2017-05-07 |
| Genre | : Double taxation |
| ISBN | : 9781402428456 |
Download Transfer Pricing Answer Book Book in PDF, ePub and Kindle
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.
| Author | : Raffaele Petruzzi |
| Publisher | : Kluwer Law International B.V. |
| Total Pages | : 338 |
| Release | : 2013-10-20 |
| Genre | : Law |
| ISBN | : 9041167331 |
Download Transfer Pricing Aspects of Intra-Group Financing Book in PDF, ePub and Kindle
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.
| Author | : Michael Lang |
| Publisher | : Kluwer Law International B.V. |
| Total Pages | : 484 |
| Release | : 2021-06-18 |
| Genre | : Law |
| ISBN | : 9403517247 |
Download Fundamentals of Transfer Pricing Book in PDF, ePub and Kindle
Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.
| Author | : J. Li |
| Publisher | : Springer |
| Total Pages | : 296 |
| Release | : 2005-09-08 |
| Genre | : Business & Economics |
| ISBN | : 0230511600 |
Download International Transfer Pricing in Asia Pacific Book in PDF, ePub and Kindle
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.
| Author | : Wagdy M. Abdallah |
| Publisher | : Praeger |
| Total Pages | : 184 |
| Release | : 1989-03-13 |
| Genre | : Business & Economics |
| ISBN | : |
Download International Transfer Pricing Policies Book in PDF, ePub and Kindle
"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
| Author | : Jens Wittendorff |
| Publisher | : Kluwer Law International B.V. |
| Total Pages | : 914 |
| Release | : 2010-01-01 |
| Genre | : Law |
| ISBN | : 9041132708 |
Download Transfer Pricing and the Arm's Length Principle in International Tax Law Book in PDF, ePub and Kindle
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.
| Author | : Michael Lang |
| Publisher | : |
| Total Pages | : 0 |
| Release | : 2019 |
| Genre | : International business enterprises |
| ISBN | : 9789041189943 |
Download Fundamentals of Transfer Pricing Book in PDF, ePub and Kindle
Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint 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), the international tax law firm L&P - Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. In analysing the topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding.
| Author | : Business International Corporation |
| Publisher | : |
| Total Pages | : 212 |
| Release | : 1991 |
| Genre | : Foreign exchange |
| ISBN | : |
Download International Transfer Pricing Book in PDF, ePub and Kindle
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.
