Asia-Pacific Transfer Pricing Handbook

Asia-Pacific Transfer Pricing Handbook
Author: Robert Feinschreiber
Publisher: John Wiley & Sons
Total Pages: 558
Release: 2012-10-03
Genre: Business & Economics
ISBN: 1118359402

An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businesses A comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders. Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad. Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the law A complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad.

Transfer Pricing Handbook

Transfer Pricing Handbook
Author: Robert Feinschreiber
Publisher: John Wiley & Sons
Total Pages: 448
Release: 2012-08-03
Genre: Business & Economics
ISBN: 1118376560

Learn OECD guidance on business taxation in multiple countries A business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying more in taxes that the share of profit it generates. The Organisation for Economic Co-operation and Development (OECD) seeks to reduce the risk of business taxation in multiple countries. Transfer Pricing Handbook explores how countries can apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. It is the ultimate comprehensive guide for companies doing business globally. Helps companies properly price their goods and services for global markets Provides defenses for transfer pricing audits Provides standards for creating comparables that multijurisdictional tax administrations will accept Guides documentation requirements and timing issues If you're doing business in more than one country, Transfer Pricing Handbook is a must-have, essential guide for simplifying OECD regulations for your global company.

International Transfer Pricing in Asia Pacific

International Transfer Pricing in Asia Pacific
Author: J. Li
Publisher: Springer
Total Pages: 296
Release: 2005-09-08
Genre: Business & Economics
ISBN: 0230511600

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.

Transfer Pricing

Transfer Pricing
Author: Alan Paisey
Publisher: Universal-Publishers
Total Pages: 152
Release: 2012
Genre: Business & Economics
ISBN: 1612335497

This book offers an introduction to transfer pricing with particular reference to China, for those who are looking for an overview that can be rapidly comprehended and who value diagrammatic images as a vehicle for learning. The subject is of importance both for Chinese and foreign personnel engaged in foreign company activity in China and for those who are similarly engaged in Chinese-owned companies already operating abroad, or which are to be extended to foreign locations.

Guide to International Transfer Pricing

Guide to International Transfer Pricing
Author: Dr A. Michael Heimert
Publisher: Kluwer Law International B.V.
Total Pages: 1074
Release: 2018-10-26
Genre: Law
ISBN: 9403501715

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.

Resolving Transfer Pricing Disputes

Resolving Transfer Pricing Disputes
Author: Eduardo Baistrocchi
Publisher: Cambridge University Press
Total Pages: 975
Release: 2012-12-06
Genre: Law
ISBN: 1139916289

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.

A Legal Guide to Doing Business in the Asia-Pacific

A Legal Guide to Doing Business in the Asia-Pacific
Author: Albert Vincent Y. Yu Chang
Publisher: American Bar Association
Total Pages: 552
Release: 2010
Genre: Business & Economics
ISBN: 9781604428438

This book provides domestic law expertise, on-the-ground experience, and a global perspective of 14 countries and jurisdictions (Australia, China, Hong Kong, India, Indonesia, Japan, Malaysia, Pakistan, Philippines, Singapore, South Korea, Taiwan, Thailand, and Vietnam) and addresses topics such as: establishing a business presence; foreign investments; operational issues; litigation and dispute resolution; and developing an exit strategy.

Evolution of APA Regime

Evolution of APA Regime
Author: Kuldeep Sharma
Publisher: Kluwer Law International B.V.
Total Pages: 252
Release: 2021-07-19
Genre: Law
ISBN: 9403535520

Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.

Vietnam Tax Guide

Vietnam Tax Guide
Author: Lorenzo Riccardi
Publisher: Springer Science & Business Media
Total Pages: 213
Release: 2013-10-14
Genre: Law
ISBN: 3319021389

Vietnam is one of the main developing countries experiencing rapid growth in East Asia. As part of ASEAN and strategically located near China and the Mekong region, Vietnam is considered a leading market between Asian and South Asian countries. Its fiscal system has recently been reformed in order to better align rules with the country’s economic development. Vietnam grants tax incentives and fiscal holidays to foreign investors and has concluded a significant number of double taxation treaties with other nations. This book describes in detail Vietnam’s complex tax system and policies, as well as major bilateral treaties in which Vietnam has entered into using country-by-country analysis. ​

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

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.