Global Transfer Pricing
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| Author | : Deloitte |
| Publisher | : Bloomsbury Professional |
| Total Pages | : 328 |
| Release | : 2020-02-27 |
| Genre | : Transfer pricing |
| ISBN | : 9781526514097 |
Now in its fourth edition, Global Transfer Pricing: Principles and Practices continues to provide a straightforward and accessible introduction to this complex and increasingly important area of business taxation. It offers readers an overall view of transfer pricing as it is practised today, including the 2017 changes to OECD transfer pricing guidance following the Base Erosion and Profit Shifting (BEPS) initiative. In addition to the theory of transfer pricing, this practical handbook explains how to implement transfer pricing models in global multinationals, how to monitor transactions to ensure compliance and how to create transfer pricing documentation. --
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 658 |
| Release | : 2022-01-20 |
| Genre | : |
| ISBN | : 9264921915 |
In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.
| Author | : Geoff Turner |
| Publisher | : Business Expert Press |
| Total Pages | : 114 |
| Release | : 2013-03-15 |
| Genre | : Business & Economics |
| ISBN | : 1606493493 |
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 | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 612 |
| Release | : 2017-07-10 |
| Genre | : |
| ISBN | : 9264265120 |
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.
| 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 | : 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.
| Author | : Robert T. Cole |
| Publisher | : Aspen Publishers |
| Total Pages | : 1302 |
| Release | : 1999 |
| Genre | : Business & Economics |
| ISBN | : |
Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.
| Author | : Wagdy M. Abdallah |
| Publisher | : Praeger |
| Total Pages | : 184 |
| Release | : 1989-03-13 |
| Genre | : Business & Economics |
| ISBN | : |
"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 | : Joel Cooper |
| Publisher | : World Bank Publications |
| Total Pages | : 275 |
| Release | : 2017-01-05 |
| Genre | : Business & Economics |
| ISBN | : 1464809704 |
Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.
| Author | : David B. Blair |
| Publisher | : |
| Total Pages | : 0 |
| Release | : 2017-05-07 |
| Genre | : Double taxation |
| ISBN | : 9781402428456 |
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.
