Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010
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Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2010-08-16
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010-08-16 with categories.
The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, the valuation, for tax purposes, of cross-border transactions between associated enterprises.
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2017
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-07-10
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2017 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-07-10 with categories.
This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010 Serbian Version
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2011-12-09
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010 Serbian Version written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011-12-09 with categories.
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administration
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Author : Aurobindo Ponniah
language : en
Publisher:
Release Date : 2010
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administration written by Aurobindo Ponniah and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010 with Income tax categories.
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations
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Author :
language : en
Publisher:
Release Date : 2009
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with categories.
Transfer Pricing Aspects Of Intra Group Financing
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Author : Raffaele Petruzzi
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2013-10-20
Transfer Pricing Aspects Of Intra Group Financing written by Raffaele Petruzzi 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 2013-10-20 with Law categories.
For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010 Edition And Transfer Pricing Features Of Selected Countries 2016
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Author :
language : en
Publisher:
Release Date : 2017
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010 Edition And Transfer Pricing Features Of Selected Countries 2016 written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with categories.
Transfer pricing is one of the most important issues for multinational companies as they strive to ensure that each company in the group earns a fair share of the profits after considering its functions and risks. Tax authorities, however, are concerned that the inter-company transfer prices are being used to reduce taxable profits in their jurisdiction. This has resulted in a sharp rise in transfer pricing regulations and enforcement, which makes transfer pricing controversies a major tax issue for companies, and particularly so in an era when base erosion and profit shifting (BEPS) issues are taking centre stage. This book contains the official text of the 2010 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, together with information on transfer pricing in selected countries. The countries were chosen on the basis of their geographical and economic importance as well as the amount of transfer pricing activity. Each country chapter provides a concise description of the current transfer pricing laws, guidelines and methodologies in practice in that particular country, and the information is presented in a domestic as well as an international context.
Annual Report On The Oecd Guidelines For Multinational Enterprises 2010 Corporate Responsibility Reinforcing A Unique Instrument
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2010-11-16
Annual Report On The Oecd Guidelines For Multinational Enterprises 2010 Corporate Responsibility Reinforcing A Unique Instrument written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010-11-16 with categories.
This Annual Report provides an account of the actions taken by the 42 adhering governments over the 12 months to June 2010 to enhance the contribution of the OECD Guidelines for Multinational Enterprises to the improved functioning of the global economy.
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010 And Transfer Pricing Features Of Selected Countries 2014
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Author : Mei June Soo
language : en
Publisher:
Release Date : 2014
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010 And Transfer Pricing Features Of Selected Countries 2014 written by Mei June Soo and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with categories.
Transfer pricing is one of the most important issues for multinational companies as they strive to ensure that each company in the group earns a fair share of the profits after considering its functions and risks. Tax authorities, however, are concerned that the inter-company transfer prices are being used to reduce taxable profits in their jurisdiction. This has resulted in a sharp rise in transfer pricing regulations and enforcement, thereby making transfer pricing controversies a major tax issue for companies.00This book contains the official text of the 2010 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, together with information on transfer pricing in selected countries. The countries were chosen on the basis of their geographical and economic importance as well as the amount of transfer pricing activity. Each country chapter provides a concise description of the current transfer pricing laws, guidelines and methodologies in practice in that particular country, and the information is presented in a domestic as well as an international context.0.
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.