Fundamentals Of International Transfer Pricing In Law And Economics

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Fundamentals Of International Transfer Pricing In Law And Economics

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Author : Wolfgang Schön
language : en
Publisher: Springer Science & Business Media
Release Date : 2012-02-15

Fundamentals Of International Transfer Pricing In Law And Economics written by Wolfgang Schön and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-02-15 with Law categories.

The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.

Klaus Vogel On Double Taxation Conventions

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Author : Ekkehart Reimert
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-01-18

Klaus Vogel On Double Taxation Conventions written by Ekkehart Reimert and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-01-18 with Law categories.

Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University

State Aid Law And Business Taxation

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Author : Isabelle Richelle
language : en
Publisher: Springer
Release Date : 2016-10-18

State Aid Law And Business Taxation written by Isabelle Richelle and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-10-18 with Law categories.

This book is a compilation of contributions exploring the impact of the European Treaty provisions regarding state aid on Member States’ legislation and administrative practice in the area of business taxation. Starting from a detailed analysis of the European Courts’ jurisprudence on Art.107 TFEU the authors lay out fundamental issues – e.g. on legal concepts like “advantage”, “selectivity” and “discrimination” – and explore current problems – in particular policy and practice regarding “harmful” tax competition within the European Union. This includes the Member States’ Code of Conduct on business taxation, the limits to anti-avoidance legislation and the options for legislation on patent boxes. The European Commission’s recent findings on preferential “rulings” are discussed as well as the general relationship between international tax law, transfer pricing standards and the European prohibition on selective fiscal aids.

Transfer Pricing In A Post Beps World

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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-20

Transfer Pricing In A Post Beps World written by Michael Lang and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-04-20 with Law categories.

The OECD’s Base Erosion and Profit Shifting (BEPS) project promises to make effective inroads into the much criticized corporate tax strategy known as aggressive transfer pricing, whereby the profitability of subsidiaries in different jurisdictions is “managed” via mispricing with the intent of minimizing the corporation’s overall tax burden. Although the OECD BEPS project is an ongoing endeavor, its accomplishments to date and developing trends are discernible. This book, including contributions by outstanding and renowned transfer pricing experts both from practice and academia, analyses these trends, and proposes reforms which would ensure that transfer pricing outcomes are better aligned with economic activities and value creation, which achieves a more equitable distribution of profits among different countries. Each chapter is dedicated to specific sections of the OECD’s BEPS Action Plan. Among the topics and issues covered are the following: – arm’s length principle and its ongoing development; – allocation of risk and recharacterization; – intangibles (both license model and cost contribution arrangements); – interest deductions and intra-group financing; – low value-adding services; – commissionaire arrangements and low-risk distributors; – attribution of profits to permanent establishments; – documentation requirements (including Country-by-Country Reporting). Within these topics, measures to identify the commercial and financial relationships inside multinational enterprises, to accurately delineate actual transactions, as well as guidance on defining risk and its allocation among entities of a multinational enterprise are discussed. The book is based on papers presented and discussed at the first Global Transfer Pricing Conference hosted in February 2016 by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business). The most up-to-date and thorough consideration of transfer pricing yet published, this book will prove invaluable for all parties currently facing questions related to transfer pricing in a post-BEPS world, especially those in charge of finding an ideal answer to them: academics, practitioners (including in-house and advisory counsel), international organizations, CEOs and CFOs of multinational enterprises, and government officials who are tax and transfer pricing experts.

Tax Transfer Pricing

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Author : Andrea Musselli
language : en
Publisher: Gruppo 24 Ore
Release Date : 2022-09-15T00:00:00+02:00

Tax Transfer Pricing written by Andrea Musselli and has been published by Gruppo 24 Ore this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-09-15T00:00:00+02:00 with Business & Economics categories.

The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.

Research Handbook On International Taxation

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Author : Yariv Brauner
language : en
Publisher: Edward Elgar Publishing
Release Date : 2020-12-25

Research Handbook On International Taxation written by Yariv Brauner and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-12-25 with Law categories.

Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.

Geopolitical Risks In Financial Reporting And Transfer Pricing

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Author : Anatol Melega
language : en
Publisher: Springer Nature
Release Date : 2025-03-04

Geopolitical Risks In Financial Reporting And Transfer Pricing written by Anatol Melega and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2025-03-04 with Business & Economics categories.

This book explores the impact of geopolitical changes on financial reporting, transfer pricing, and foreign investment flows. It focuses on how geopolitical instability affects companies in emerging and developing economies, highlighting shifts in international reporting and risk management. The main objectives are to analyze transformations in the internationalization of business, assess the impact of accounting information on investment attraction, and evaluate tax policies. In the context of a changing geopolitical environment and the rise of economic multipolarity, particularly with a focus on BRICS economies, the book addresses the strategic adaptations needed in financial reporting and compliance. Offering an in-depth perspective on the complexity and interconnectedness of today's risks, this book is an essential guide for scholars and financial professionals navigating the global economic landscape.

Research Handbook On European Union Taxation Law

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Author : Christiana HJI Panayi
language : en
Publisher: Edward Elgar Publishing
Release Date : 2020-01-31

Research Handbook On European Union Taxation Law written by Christiana HJI Panayi and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-01-31 with Law categories.

Offering a comprehensive exploration of EU taxation law, this engaging Research Handbook investigates the associated legal principles in the context of both direct and indirect taxation. The important issues and debates arising from these general principles are expertly unpicked, with leading scholars examining the status quo as well as setting out a clear agenda for future research.

Cross Border Mergers And Acquisitions

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Author : Mohammad Bedier
language : en
Publisher: Edward Elgar Publishing
Release Date : 2018-09-28

Cross Border Mergers And Acquisitions written by Mohammad Bedier and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-09-28 with Law categories.

This book provides the reader with an overview of the origin of corporations and the history of mergers and acquisitions. It demystifies the dynamics of mergers and identifies the unique impediments facing cross-border mergers and acquisitions, with great attention to the pre-merger control laws and regulations, in several regions (US, EU, and Middle East). Most importantly, it discusses and assesses merger deregulation and other key reforming proposals.

Residence And Economic Substance Of Subsidiary Corporations In International And European Tax Law

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Author : Savvas Kostikidis
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2024-10-10

Residence And Economic Substance Of Subsidiary Corporations In International And European Tax Law written by Savvas Kostikidis and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-10-10 with Law categories.

Series on International Taxation Residence and Economic Substance of Subsidiary Corporations in International and European Tax Law It is well known that multinational corporations establish foreign subsidiaries in great measure to reduce their worldwide tax burden. This groundbreaking book examines the content of the substance requirement in double tax convention residence rules, transfer pricing rules, anti-abuse rules, and controlled foreign corporation rules in the context of international and EU tax law, disentangling the complex relationship between the substance requirements in these four sets of legal rules. Following a descriptive-analytic method, for each substance requirement of the four sets of legal rules, the discussion deals with the content of economic substance in complex scenarios, for example: holding companies; special purpose vehicles; loss-making subsidiaries; subsidiaries with management in more than one state; subsidiaries managed by the parent company; outsourcing; and subsidiaries ‘borrowing’ the substance of other group companies. The author introduces a new method of assessment of substance requirements, offering practical solutions for their uniform application in international and European tax law. In its thorough examination of how substance requirements work and how they are interrelated among different sets of tax rules, this book has no peers. It will be welcomed by taxation practitioners and corporate counsel in Europe and worldwide.