Transfer Pricing Answer Book 2012 Edition
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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.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 110 |
Release | : 2012-01-18 |
Genre | : |
ISBN | : 9264169466 |
This report addresses the practical administration of transfer pricing programmes by tax administrations.
Author | : United Nations |
Publisher | : |
Total Pages | : 672 |
Release | : 2017 |
Genre | : Business & Economics |
ISBN | : |
The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.
Author | : Aitor Navarro |
Publisher | : |
Total Pages | : |
Release | : 2017 |
Genre | : |
ISBN | : 9789087224363 |
Author | : American Bar Association. House of Delegates |
Publisher | : American Bar Association |
Total Pages | : 216 |
Release | : 2007 |
Genre | : Law |
ISBN | : 9781590318737 |
The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Author | : International Monetary Fund. Fiscal Affairs Dept. |
Publisher | : International Monetary Fund |
Total Pages | : 82 |
Release | : 2012-08-16 |
Genre | : Business & Economics |
ISBN | : 1498340067 |
Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 91 |
Release | : 2013-02-12 |
Genre | : |
ISBN | : 9264192743 |
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
Author | : Steve Edge |
Publisher | : |
Total Pages | : 0 |
Release | : 2023 |
Genre | : |
ISBN | : 9781804491782 |
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 | : Centre on Transnational Corporations (United Nations) |
Publisher | : New York : United Nations |
Total Pages | : 124 |
Release | : 1988 |
Genre | : Business & Economics |
ISBN | : |
Study on the income tax structure applicable to multinational companies operating in developing countries with reference to double taxation treaties and transfer pricing problems.