Global Transfer Pricing Solutions
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Global Transfer Pricing Solutions
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Author : Judy S. Kuan
language : en
Publisher: WorldTrade Executive, Inc.
Release Date : 2004-11
Global Transfer Pricing Solutions written by Judy S. Kuan and has been published by WorldTrade Executive, Inc. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004-11 with Business & Economics categories.
GLOBAL TRANSFER PRICING SOLUTIONS: 2004 covers the major transfer pricing regimes around the world with in-depth discussion and analysis of such topics as proactive transfer pricing management of post-merger integrations, e-commerce and intellectual property. This report was prepared by members of major law and accounting firms and senior international transfer pricing professionals at the largest multinationals. It covers a wide range of tools and techniques relevant to transfer pricing in Asia, Europe, Latin America, and North America.
Global Transfer Pricing Solutions
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Author : Katherine Dimancescu
language : en
Publisher: Worldtrade Executive
Release Date : 2007
Global Transfer Pricing Solutions written by Katherine Dimancescu and has been published by Worldtrade Executive this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Business & Economics categories.
This text discusses what the new era of global tax enforcement and administration means for multinational companies, how it will affect crossborder tax planning, and what steps corporate tax departments can take to manage compliance and risk both globally and locally.
Global Transfer Pricing Solutions
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Author : WorldTrade Executive, Inc
language : en
Publisher:
Release Date : 2002-08-01
Global Transfer Pricing Solutions written by WorldTrade Executive, Inc and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2002-08-01 with International business enterprises categories.
Global Transfer Pricing Solutions
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Author : Katherine Dimancescu
language : en
Publisher: Worldtrade Executive
Release Date : 2008
Global Transfer Pricing Solutions written by Katherine Dimancescu and has been published by Worldtrade Executive this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Business & Economics categories.
Analysis and description of the major worldwide transfer pricing regimes in Asia, Europe, Latin America, Russia/Eurasia, and North America. The issues discussed are (amongst others) transfer pricing management, intellectual property and electronic commerce.
Transfer Pricing And Corporate Taxation
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Author : Elizabeth King
language : en
Publisher: Springer Science & Business Media
Release Date : 2008-10-11
Transfer Pricing And Corporate Taxation written by Elizabeth King 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 2008-10-11 with Business & Economics categories.
National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.
Guide To International Transfer Pricing
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Author : Dr A. Michael Heimert
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2018-10-26
Guide To International Transfer Pricing written by Dr A. Michael Heimert 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 2018-10-26 with Law categories.
The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.
Advance Pricing Agreements
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Author : Michelle Markham
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2012-06-28
Advance Pricing Agreements written by Michelle Markham 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 2012-06-28 with Law categories.
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.
Transfer Pricing And Financial Transactions
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2022-03-16
Transfer Pricing And Financial Transactions written by Michael Lang and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-03-16 with Law categories.
Transfer pricing and financial transactions: Issues and developments Since years, issues related to transfer pricing and intra-group financing are prominent in the agendas of both taxpayers and governments. The extreme relevance of these topics and the need to address them has attracted the interest of various international organizations for a long time. Already in 1972, the OECD emphasized that these topics required further attention, and the 1979 OECD Transfer Pricing Report dedicated an entire chapter to issues concerning loans. However, the first OECD Transfer Pricing Guidelines issued in 1995 did not include a chapter on these issues. Twenty-five years later, in February 2020, the OECD finally released its 2022 Transfer Pricing Guidelines on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines. Meanwhile, in 2021, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries. With those welcomed recent developments from the OECD and the UN, the topic is now being extensively discussed, especially considering the necessary implementation of the guidance at the national level and the future answers from the tax courts at national and European levels when dealing with this matter. This publication discusses the most important issues and recent developments related to this topic. Beginning with an in-depth analysis on the accurate delineation of financial transactions, it further deals with the specific transactions concerning loans, financial guarantees, and cash pooling. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium held in October 2021 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.
Transfer Pricing And Business Restructurings
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2023-09-19
Transfer Pricing And Business Restructurings written by Michael Lang and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-09-19 with Law categories.
Transfer pricing and business restructurings: issues and developments In the ever-evolving global landscape, the ability of businesses to swiftly adapt is crucial for maintaining relevance and competitiveness. This imperative holds true for multinationals, which frequently engage in strategic restructuring of their operations, assets, and resources to realign with the dynamic shifts in market conditions. This dynamic approach enhances operational efficiency, cuts costs, and optimizes financial performance. However, the intricacies of restructuring, especially in the context of transfer pricing, pose considerable challenges. Despite elaborate guidance from the OECD and UN, transfer pricing considerations in business restructuring remain complex. Determining appropriate transfer pricing methodologies, finding comparable transactions, and ensuring accurate documentation present hurdles for both multinationals and tax administrations. This publication discusses the most important issues and recent developments related to this theme. It attempts to cover various issues related to business restructuring, including delineation and recognition, remuneration of restructuring and post-restructuring, and other relevant issues such as exit taxes, location savings, permanent establishments, and implications of COVID-19. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, that took place in October 2022 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.
U S Transfer Pricing Sourcebook
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Author : Amanda Johnson
language : en
Publisher: WorldTrade Executive, Inc.
Release Date : 2005-03
U S Transfer Pricing Sourcebook written by Amanda Johnson and has been published by WorldTrade Executive, Inc. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005-03 with Business & Economics categories.
U.S. TRANSFER PRICING SOURCEBOOK is a single-volume report designed to advise international finance professionals on the cutting edge tools and techniques being developed and applied by leading consultants. This sourcebook provides strategies on Intercompany Sales, Intercompany Service transactions, Cross-Border licensing, and Cost Sharing agreements.