Global Focus On Transparency Transfer Pricing Documentation And Audits
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Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 148 |
Release | : 2015-03-16 |
Genre | : |
ISBN | : 9264231498 |
This report contains the 2014 “Phase 2: Implementation of the Standards in Practice” Global Forum review of Hungary.
Author | : Pauline Weetman |
Publisher | : Routledge |
Total Pages | : 425 |
Release | : 2020-02-19 |
Genre | : Business & Economics |
ISBN | : 0429774605 |
This textbook provides a comprehensive overview of international corporate reporting which enhances students’ understanding of diversity and convergence in the field. The authors discuss the institutional and cultural context in which international corporate reporting has developed over the years as well as the global reach of IFRS Standards from the IASB throughout and beyond the European Union, into interest groups and emerging economies. Other key elements explored throughout the book include assurance through auditing and corporate governance, narrative reporting, strategic and corporate social responsibility, group accounting, current accounting issues and taxation in corporate reports. Indicative research examples show how the methods used in research papers may be understood and applied. Case studies outline short projects based on corporate cases, with related links to material on corporate websites. Helpful and reliable sources of information and data are identified through hyperlinks to accessible websites. End-of-chapter questions encourage discussion of the main issues. Throughout there is a focus on accountability and the information needs of stakeholders. This new edition of a classic text is fully revised and updated in order to remain essential reading for students of international accounting and corporate reporting globally. The book will be an invaluable resource for postgraduate taught programmes and final-year undergraduate courses in accounting, finance and business studies.
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.
Author | : Organisation for Economic Co-operation and Development |
Publisher | : Organisation for Economic Co-operation and Development |
Total Pages | : 76 |
Release | : 1995 |
Genre | : Business & Economics |
ISBN | : |
Includes 1999 update. 1998 update in back.
Author | : Michael Lang |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 484 |
Release | : 2021-06-18 |
Genre | : Law |
ISBN | : 9403517247 |
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 | : Raffaele Petruzzi |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 549 |
Release | : 2022-06-20 |
Genre | : Law |
ISBN | : 9403535202 |
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.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 228 |
Release | : 2011-06-27 |
Genre | : |
ISBN | : 9789264107236 |
This handbook provides guidance for the assessment teams and the reviewed jurisdictions that are participating in the Global Forum on Transparency and Exchange of Information for Tax Purposes (the “Global Forum”) peer reviews and non-member reviews.
Author | : ?ahin Duran, Deniz |
Publisher | : IGI Global |
Total Pages | : 326 |
Release | : 2019-03-29 |
Genre | : Business & Economics |
ISBN | : 1522575650 |
Although the concept of international public goods has been established, new international public needs arise by the day. For example, while there are many taxation problems and debates that have not yet been resolved internationally, many new tax-related problems like international transfer pricing, taxation of virtual profits, and taxation of electronic commerce are being added. These issues require studies that will discuss a new agenda and propose solutions for these dilemmas and problems. Global Challenges in Public Finance and International Relations provides an innovative and systematic examination of the present international financial events and institutions, international financial relations, and fiscal difficulties and dilemmas in order to discuss solutions for potential problems in the postmodern world. Highlighting topics such as international aid, public debt, and corporate governance, this publication is designed for executives, academicians, researchers, and students of public finance.
Author | : Michael Lang |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 288 |
Release | : 2016-04-24 |
Genre | : Law |
ISBN | : 9041183760 |
Derived from the renowned multi-volume International Encyclopaedia of Laws, this book describes the social security regime in Slovenia. It conveys a clear working knowledge of the legal mechanics affecting health care, employment injuries and occupational diseases, incapacity to work, pensions, survivors’ benefits, unemployment benefits and services, and family benefits. The analysis covers the field of application, conditions for entitlement, calculation of benefits, financing, the institutional framework, and relevant law enforcement and controls. Allowances for retirees, employees, public sector workers, the self-employed, and the handicapped are all clearly explained, along with full details of claims, adjudication procedures, and appeals. Succinct yet eminently practical, the book will be a valuable resource for lawyers handling social security matters in Slovenia. It will be of practical utility to those both in public service and private practice called on to develop and to apply social security law and policy, and of special interest as a contribution to the comparative study of social security systems.
Author | : Michelle Markham |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 377 |
Release | : 2012-06-28 |
Genre | : Law |
ISBN | : 9041140727 |
Transfer pricing (the pricing of cross-border intra-firm transactions between related parties) is now the top international tax issue faced by multinational enterprises. In an international taxation environment characterized by rigorous enforcement of transfer pricing documentation, disclosure, and audit processes, a need has arisen for multinationals to be cognizant of the impact of their ‘tax risk appetite’ on their relationship with taxation authorities and to be aware of how best to manage their transfer pricing arrangements. The most promising development has been the growing commitment to Advance Pricing Agreements (APAs) – arrangements made prospectively between a multinational taxpayer and one or more revenue authorities, agreeing on an appropriate set of criteria for the determination of the transfer pricing of the covered transactions over a period of time. This is the first book to offer expert insights on APAs from a practical perspective. By focusing on the United States and Australia, the two countries that were at the forefront of adopting APAs and whose wealth of experience over two decades confirms their APA programs as the global paradigms, the author is able to highlight the advantages and disadvantages of pursuing an APA and to shed light on the powerful efficacy of this strategy for avoiding transfer pricing disputes. In addition, the author enlists the views of revenue authorities, transfer pricing practitioners, and corporate counsel who deal with the realities of transfer pricing assessment and compliance on an ongoing basis, offering acute insight into how APAs really work in a practical way. This book contributes to the body of knowledge on APAs in the context of transfer pricing by providing in-depth scrutiny of the most important issues surrounding this critical area, and by examining innovations in APAs in the United States and in Australia. Its unmatched coverage will be welcomed by tax experts at law firms and multinational companies as well as by revenue officials, policymakers, and scholars and researchers in international taxation.