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| Author | : Marc M. Levey |
| Publisher | : CCH |
| Total Pages | : 232 |
| Release | : 2006 |
| Genre | : Business & Economics |
| ISBN | : 9780808015536 |
This book gives an overview of the basic principles of transfer pricing and U.S. transfer pricing rules, and the impact of transfer pricing on other issues such as customs valuation, Section 404 of the Sarbanes-Oxley Act of 2002, and FASB Interpretation no. 48.
| Author | : Marc M. Levey |
| Publisher | : CCH Incorporated |
| Total Pages | : 0 |
| Release | : 2010 |
| Genre | : Transfer pricing |
| ISBN | : 9780808021667 |
Transfer Pricing: Rules, Compliance and Controversy offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Throughout the book, the authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures.
| 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 | : Paul Sutton |
| Publisher | : |
| Total Pages | : 146 |
| Release | : 2019-03-11 |
| Genre | : Business & Economics |
| ISBN | : 9781912687183 |
This book is a practical resource for finance, tax and transfer pricing professionals, and for anyone involved in designing, implementing, maintaining or reviewing intercompany agreements for multinational groups.
| Author | : Cecil K. Nazareth |
| Publisher | : Bookbaby |
| Total Pages | : 274 |
| Release | : 2022-02-24 |
| Genre | : Business & Economics |
| ISBN | : 9781667825847 |
As the world grows increasingly connected, global accounting standards are converging. Whether practitioners, CFOs, controllers or students, top U.S. accountants know it's essential to understand International Financial Reporting Standards (IFRS) thoroughly if they are advising their companies (or clients) who do business across borders. Likewise, non-U.S. accountants know they must now understand the nuances of US GAAP (Generally Accepted Accounting Principles). Global Accounting: 2021 and Beyond helps financial professionals worldwide understand the similarities and differences between US GAAP and IFRS. As a result, they're better equipped to advise foreign corporations operating in the U.S. and U.S. companies operating abroad. Written by Cecil K. Nazareth ACA, CPA, MBA, a widely-respected thought leader in international tax and accounting circles. A member of the AICPA's International Tax Issues Task Force Nazareth shares his three-decades of international tax and accounting expertise, with a heavy emphasis on small to midsize companies, subsidiaries of foreign parents, and high-net-worth individuals and families across the globe. He's a highly sought-after speaker and university professor for both national and international locations. Tax firms around the world call Cecil to conduct sessions for their teams. He's also the author of International Tax & Compliance Handbook (2018).
| 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 | : 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.
| Author | : Oliver Treidler |
| Publisher | : Springer Nature |
| Total Pages | : 145 |
| Release | : 2019-09-12 |
| Genre | : Business & Economics |
| ISBN | : 3030250857 |
This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm’s length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book’s content is applicable to a global context.
| Author | : Gio Wiederhold |
| Publisher | : Springer Science & Business Media |
| Total Pages | : 602 |
| Release | : 2013-08-13 |
| Genre | : Business & Economics |
| ISBN | : 1461466113 |
Valuing Intellectual Capital provides readers with prescriptive strategies and practical insights for estimating the value of intellectual property (IP) and the people who create that IP within multinational companies. This book addresses the crucial topic of taxation from a rigorous and quantitative perspective, backed by experience and original research that illustrates how large corporations need to measure the worth of their intangible assets. Each method in the text is applied through the lens of a model corporation, in order for readers to understand and quantify the operation of a real-world multinational enterprise and pinpoint how companies easily misvalue their intellectual capital when transferring IP rights to offshore tax havens. The effect contributes to the issues that can lead to budgetary crises, such as the so-called “fiscal cliff” that was partially averted by passage of the American Taxpayer Relief Act on New Year’s day 2013. This book also features a chapter containing recommendations for a fair and balanced corporate tax structure free of misvaluation and questionable mechanisms. CFOs, corporate auditors, corporate financial analysts, corporate financial planners, economists, and journalists working with issues of taxation will benefit from the concepts and background presented in the book. The material clearly indicates how a trustworthy valuation of intellectual capital allows a realistic assessment of a company’s income, earnings, and obligations. Because of the intense interest in the topic of corporate tax avoidance the material is organized to be accessible to a broad audience.
| 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.
