Le Novit Del Transfer Pricing
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Fundamentals Of Transfer Pricing
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-06-18
Fundamentals Of Transfer Pricing 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 2021-06-18 with Law categories.
Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.
Transfer Pricing
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Author : Studio Trivoli Staff
language : en
Publisher: Springer
Release Date : 2013-12-20
Transfer Pricing written by Studio Trivoli Staff and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-12-20 with Business & Economics categories.
As a part of the provisions governing the subject of the measurement of the income of business enterprises, the fifth paragraph, sub paragraph b), of article 53 of the Presidential Decree no. 597 of 29 September, 1973, provides, as it is well known, that "the difference between the normal value of goods and services, and the consideration for transfers made and for services rendered to companies, whose legal seat or administrative headquarters and whose main object are not in the Italian territory, and which either directly or indirectly control the enterprise, or are controlled by the same company that controls the enterprise", is tobe included in the proceeds. The second paragraph of the successive article 56 further states that the cost of acquisition of the goods transferred and of the services rendered by the same enterprises is to be curtailed of any surplus tn respect of the normal value. The same provision also applies to the goods transferred and the services rendered by companies not having in Italy their legal seat or their administrative office or the main object of their activity, for account of which the enterprise carries out an activity for the sale and placement of raw materials or goods, or for the manufacturing or processing of products.
Introduction To Transfer Pricing
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Author : Jerome Monsenego
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-11-22
Introduction To Transfer Pricing written by Jerome Monsenego 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 2022-11-22 with Law categories.
Transfer pricing refers to the pricing of cross-border intercompany transactions. Transfer prices influence the tax base of multinational enterprises, and thus also the fiscal revenues of the countries where they are doing business. The importance of transfer pricing has significantly expanded over time and culminated with the work of the OECD on Base Erosion and Profit Shifting (BEPS). With the globalisation of business activities, the need for States to prevent tax avoidance, and the risk of double taxation faced by multinational enterprises, transfer pricing has become a key question for multinational enterprises and tax administrations alike. Introduction to Transfer Pricing intends at providing a general introduction to the fundamentals of transfer pricing. The book is focused on explanations of the principles that apply, albeit to various extents, in most countries. Although the majority of these principles are provided by the OECD the views of other international organisations – in particular the United Nations and the European Union – are also taken into account. Moreover, the book illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when conducting cross-border business activities. Also included are relevant court cases from a variety of countries. Among the issues and topics covered are the following: the arm’s length principle in theory and practice; transfer pricing methods; intercompany transactions involving intangibles and financial transactions; common types of transfer pricing models; cross-border business restructurings; the substance requirement for transfer pricing purposes; attribution of profits to permanent establishments; and the prevention and resolution of transfer pricing disputes. This second edition was updated based on the 2022 OECD Transfer Pricing Guidelines and the 2021 UN Transfer Pricing Manual.
The Transfer Pricing Law Review
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Author : Steve Edge
language : en
Publisher:
Release Date : 2017
The Transfer Pricing Law Review written by Steve Edge and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with Transfer pricing categories.
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.
Transfer Pricing In Action
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Author : Aydin Hayri
language : en
Publisher: Kluwer Law International
Release Date : 2013
Transfer Pricing In Action written by Aydin Hayri and has been published by Kluwer Law International this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with Transfer pricing categories.
This book provides an overview of the abstract theory of transfer pricing and its everyday practice. It is an extended hypothetical case history, presented in narrative style illustrated with graphics. It gives details of transfer pricing planning and how the process engages and affects the ambitions, insights, and interactions of the group of business people and advisors involved. The book contains the following chapters: (1) MSell - a fast growth company considers corporate taxation; (2) Big tax proposal, rejected; (3) The inevitable growing pains, and state tax planning ; (4) Going international, the Canadian expansion; (5) Further expansion: the United Kingdom and greater Europe; (6) The European distributors and a surprising development, or two; (7) Services transactions: US headquarter and support services for Europe; (8) Intangibles licensing transaction, with gusto; (9) Intra-European structuring; (10) Sourcing; (11) Branding, and a new CEO; (12) Planning for a new global business model; (13) Designing and implementing the new global business model; (14) A (rather unpleasant) Thanksgiving surprise; and a timeline figure.
International Transfer Pricing
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Author :
language : en
Publisher:
Release Date : 1991
International Transfer Pricing written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1991 with categories.
The Transfer Pricing Law Review
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Author :
language : en
Publisher:
Release Date : 2019
The Transfer Pricing Law Review written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with categories.
Introduction To Transfer Pricing
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Author : Jerome Monsenego
language : en
Publisher:
Release Date : 2013-01-01
Introduction To Transfer Pricing written by Jerome Monsenego and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-01-01 with Business & Economics categories.
Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.
International Transfer Pricing
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Author : Richard Sansing
language : en
Publisher:
Release Date : 2014-12-19
International Transfer Pricing written by Richard Sansing and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-12-19 with Business & Economics categories.
International Transfer Pricing reviews this important literature emphasizing the accounting and tax practitioner literatures, while incorporating the most important contributions from the economics and legal research literatures.