Transfer Pricing

Transfer Pricing
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.

Transfer Pricing Answer Book 2014

Transfer Pricing Answer Book 2014
Author: David B. Blair
Publisher:
Total Pages: 0
Release: 2014-06-07
Genre: Double taxation
ISBN: 9781402421709

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 2013 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 2013 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

Transfer Pricing Manual

Transfer Pricing Manual
Author: Gareth Green
Publisher:
Total Pages: 446
Release: 2008-01-01
Genre: International business enterprises
ISBN: 9780906524145

United Nations Practical Manual on Transfer Pricing for Developing Countries 2017

United Nations Practical Manual on Transfer Pricing for Developing Countries 2017
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.

Practical Guide to U.S. Transfer Pricing

Practical Guide to U.S. Transfer Pricing
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.

Model Tax Convention on Income and on Capital 2014 (Full Version)

Model Tax Convention on Income and on Capital 2014 (Full Version)
Author: OECD
Publisher: OECD Publishing
Total Pages: 2289
Release: 2015-10-30
Genre:
ISBN: 9264239081

This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July 2014.

Transfer Pricing and the Arm's Length Principle After BEPS

Transfer Pricing and the Arm's Length Principle After BEPS
Author: Richard S. Collier
Publisher: Oxford University Press, USA
Total Pages: 336
Release: 2017
Genre: Law
ISBN: 9780198802914

This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS project, and describes the principal problems that had arisen with those rules. The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and the problems that remain after BEPS. It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic. This book is the most detailed and up-to-date publication on this highly topical and often controversial topic.

Transfer Prices and Management Accounting

Transfer Prices and Management Accounting
Author: Peter Schuster
Publisher: Springer
Total Pages: 78
Release: 2015-02-13
Genre: Business & Economics
ISBN: 3319147501

Transfer prices are of dominant importance in company practice and a decentralised organisation, e.g. a profit centre-organisation, is most-widely used. This textbook takes an innovative controversial approach by looking at functions of transfer prices and how different types of transfer prices can fulfil them. Suggestions common in other textbooks will be picked up and it will be shown why they do not contribute to solve the problems companies face. With support of numerous examples and exercises a conceptual understanding of this most relevant management topic will be developed. Transfer prices are an issue in most advanced courses on Management Accounting and/or Management Control and their analysis receives increasing attention. They are covered in one chapter in almost all management accounting textbooks. This often leads to serious oversimplifications and reductions of contents. This books aims at filling this gap and to provide a concise and controversial view on the topic.

Model Rules of Professional Conduct

Model Rules of Professional Conduct
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.