Oecd G20 Base Erosion And Profit Shifting Project Aligning Transfer Pricing Outcomes With Value Creation Actions 8 10 2015 Final Reports

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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.

Transfer Pricing And Value Creation

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Author : Raffaele Petruzzi
language : en
Publisher: Linde Verlag GmbH
Release Date : 2019-09-02

Transfer Pricing And Value Creation written by Raffaele Petruzzi 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 2019-09-02 with Law categories.

Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.

Corporate Income Taxes Under Pressure

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Author : Ruud A. de Mooij
language : en
Publisher: International Monetary Fund
Release Date : 2021-02-26

Corporate Income Taxes Under Pressure written by Ruud A. de Mooij and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-02-26 with Business & Economics categories.

The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.

Transfer Pricing Developments Around The World 2022

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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-10-11

Transfer Pricing Developments Around The World 2022 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 2022-10-11 with Law categories.

Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with a far-reaching impact on countries’ legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments. Transfer Pricing Developments in the European Union. Transfer Pricing Developments in the United States. Transfer Pricing Developments in Developing Countries and Emerging Economies. Recent Developments on Transfer Pricing in the Post-Covid-19 Era. Recent Developments on Transfer Pricing and Substance. Recent Developments on Transfer Pricing and Business Restructurings. Recent Developments on Transfer Pricing and New Technologies. The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players, including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating efficient dialog and a coordinated approach to transfer pricing in the future.

Virtues And Fallacies Of Vat An Evaluation After 50 Years

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Author : Robert F. van Brederode
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-08-09

Virtues And Fallacies Of Vat An Evaluation After 50 Years written by Robert F. van Brederode 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 2021-08-09 with Law categories.

Value-added tax (VAT) is a mainstay of revenue systems in more than 160 countries. Because consumption is a more stable revenue base than other tax bases, VAT is less distorting and hence more likely to encourage investment, savings, optimum labor supply decisions, and growth. VAT is not without criticism however, and faces its own specific technical and policy challenges. This book, the first to thoroughly evaluate VAT from a global policy perspective after over 50 years of experience with its intricacies, offers authoritative perspectives on VAT’s full spectrum—from its signal successes to the subtle ways its application can undermine revenue performance and economic neutrality. The contributors—leading tax practitioners and academics—examine the key policy issues and topics that are crucially relevant for measuring the success of the tax in the first part of the book, including: revenue generation and revenue efficiency; single rate versus multiple rates; susceptibility to fraud; exemptions and exceptions; compliance cost for businesses; policy and compliance gaps in revenue collection; adjustment rules caused by the transactional nature of the tax; transfer pricing issues; treatment of vouchers; permanent establishments and holding companies; payment of refunds; cross-border digital transactions; and supplies for free or below cost price. The second part offers six country reports—on New Zealand, Japan, China, Colombia, Ethiopia, and India—to demonstrate the different ways in which VAT operates in a variety of national economies. Whether a government is contemplating the imposition of a general consumption tax for the first time or new rules for applying an existing one, it is important for policymakers to keep central the aim to design a tax that realizes optimal efficiency and causes minimal distortions. This invaluable book serves as an expert guide to VAT policy development in this area. It will be welcomed not only by concerned government officials but also by tax professionals (both lawyers and accountants) and academics in tax law.

Reconstructing The International Tax System

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Author : Elizabeth Rosenthal
language : en
Publisher: Springer Nature
Release Date : 2025-05-27

Reconstructing The International Tax System written by Elizabeth Rosenthal and has been published by Springer Nature this book supported file pdf, txt, epub, kindle and other format this book has been release on 2025-05-27 with Business & Economics categories.

Source-based taxation and the arm’s length standard have been foundational elements of the international tax system for many decades. With the advent of the highly digitalized platform firm, the OECD and many other stakeholders assert that these principles have been rendered obsolete. In their stead, these stakeholders have proposed an alternative hybrid international tax system. Under this proposed hybrid system, the long-standing profit allocation rules would be applied in the first instance to determine the preliminary attribution of in-scope multinational firms’ taxable income to individual taxing jurisdictions. These results would then be subject to a secondary reallocation designed to ensure that a portion of such firms’ taxable income is attributed to, and taxable by, jurisdictions in which consumers and users reside (“market jurisdictions”). This secondary allocation – the core of the OECD’s Pillar One and an essential element of its two-pronged “Pillar One-Pillar Two Solution” – explicitly deviates from both the arm’s length standard and the principle of source-based taxation. For many reasons, examined in this book, the OECD’s Pillar One would not provide for the effective taxation of highly digitalized platform firms, and, by extension, it would not stabilize the international tax system. The author argues that source-based taxation and the arm’s length standard are entirely compatible with the attribution of a portion of highly digitalized platform firms’ taxable income to market jurisdictions. However, new transfer pricing methodologies and a revised definition of ‘control’ for transfer pricing purposes are required to achieve this result. Combining important findings and insights from academic research in a variety of fields with the author’s extensive practical experience in both public and private spheres, this book is appropriate for academics as well as private sector advisors in the fields of transfer pricing and international tax, chief financial officers of multinational corporations and tax policy analysts.

Limitation On Benefits Clauses In Double Taxation Conventions

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Author : Félix Alberto Vega Borrego
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24

Limitation On Benefits Clauses In Double Taxation Conventions written by Félix Alberto Vega Borrego 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 2016-04-24 with Law categories.

Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.

Fundamentals Of Transfer Pricing

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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2025-05-19

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 2025-05-19 with Law categories.

Fundamentals of Transfer Pricing Volume 1: Principles and Practice Edited by Raffaele Petruzzi, Giammarco Cottani & Michael Lang Transfer pricing is one of the most important and complex topics in international taxation. Recognising its significance, most countries in the world have introduced transfer pricing rules in their domestic tax systems. This book, the first of a three-volume series, explains in a clear and simple manner the most important transfer pricing topics, with a collection of incisive and wide-ranging perspectives from representatives of academia, tax law practice, multinational companies, advisory groups, national tax authorities, and international organisations from all over the globe. The contributions collectively offer a comprehensive guide to the practical application of transfer pricing rules, covering various aspects as the following: introduction to transfer pricing; accurate delineation and recognition of actual transactions; transfer pricing methods; comparability analysis; transfer pricing audits and litigation; administrative approaches to preventing and resolving transfer pricing disputes; transfer pricing documentation; attribution of profits to permanent establishments; transfer pricing and specific transactions; use of new technologies in transfer pricing; and interplay between transfer pricing and other rules. This book delves into both foundational concepts and emerging trends in transfer pricing, providing readers with the tools to understand its dynamic application in real-world scenarios. By analysing examples, case studies, and the implications of recent judicial precedents, it bridges the gap between fundamental principles and practical implementations. The application of transfer pricing legislation remains one of the most challenging tasks for taxpayers and tax authorities around the world. With this comprehensive source of practical guidance, tax lawyers, in-house tax counsels, government officials, academics, advisory firms, and the business community worldwide will have all the support they need to move forward in tackling this complex aspect of the current tax environment.

Limiting Base Erosion

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Author : Erik Pinetz
language : en
Publisher: Linde Verlag GmbH
Release Date : 2017-08-30

Limiting Base Erosion written by Erik Pinetz 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 2017-08-30 with Law categories.

Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation. This book deals especially with four key areas of interest:Limiting base erosion by neutralizing the effects of hybrid mismatch arrangementsLimiting base erosion by strengthening CFC rulesMeasures against base erosion via interest deductions and other financial paymentsLimiting base erosion by improving transfer pricing rules.On that basis, 27 concrete topics were chosen in order to address the four key areas of interest from different viewpoints. Base erosion and the challenges they present: read more in “Limiting Base Erosion”.

Transfer Pricing Developments Around The World 2017

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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24

Transfer Pricing Developments Around The World 2017 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 2016-04-24 with Law categories.

Derived from the renowned multi-volume International Encyclopaedia of Laws, this book describes the social security regime in Slovenia. It conveys a clear working knowledge of the legal mechanics affecting health care, employment injuries and occupational diseases, incapacity to work, pensions, survivors’ benefits, unemployment benefits and services, and family benefits. The analysis covers the field of application, conditions for entitlement, calculation of benefits, financing, the institutional framework, and relevant law enforcement and controls. Allowances for retirees, employees, public sector workers, the self-employed, and the handicapped are all clearly explained, along with full details of claims, adjudication procedures, and appeals. Succinct yet eminently practical, the book will be a valuable resource for lawyers handling social security matters in Slovenia. It will be of practical utility to those both in public service and private practice called on to develop and to apply social security law and policy, and of special interest as a contribution to the comparative study of social security systems.