Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010 And Transfer Pricing Features Of Selected Countries 2014
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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 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.
Peru
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Author : International Monetary Fund. Western Hemisphere Dept.
language : en
Publisher: International Monetary Fund
Release Date : 2016-07-15
Peru written by International Monetary Fund. Western Hemisphere Dept. 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 2016-07-15 with Business & Economics categories.
This Selected Issues paper presents a comparative analysis of the macroeconomic adjustment in Chile, Colombia, and Peru to commodity terms-of-trade shocks. The study is done in two steps: (1) an analysis of the impulse responses of key macroeconomic variables to terms-of-trade shocks and (2) an event study of the adjustment to the recent decline in commodity prices. The experiences of these countries highlight the importance of flexible exchange rates to help with the adjustment to lower commodity prices, and staying vigilant in addressing depreciation pressures on inflation through tightening monetary policies. On the fiscal front, evidence shows that greater fiscal space, like that of Chile and Peru, gives more room for accommodating terms-of-trade shocks.
Covid 19 Pandemic Impact On New Economy Development And Societal Change
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Author : Popescu, Cristina Raluca Gh.
language : en
Publisher: IGI Global
Release Date : 2021-12-17
Covid 19 Pandemic Impact On New Economy Development And Societal Change written by Popescu, Cristina Raluca Gh. and has been published by IGI Global this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-12-17 with Business & Economics categories.
Globalization and technological advances have the immense power to create a new economy, address sustainability concerns, and facilitate societal changes. In addition, the COVID-19 pandemic has led to notable modifications in the world economy and society that require adjustments to business models, as well as our way of life. It is critical to understand these new models in our changing society for businesses to not only survive, but to thrive. COVID-19 Pandemic Impact on New Economy Development and Societal Change provides an updated view of the newest trends, novel practices, and latest tendencies concerning the manner of shaping the new economy and accelerating societal change, demonstrating the crucial importance of rethinking the world’s models, priorities, and strategies while seeking a more responsible path for humanity. Covering topics such as tourism and salesmanship skills, this publication is ideal for academicians, researchers, scientists, scholars, practitioners, industry professionals, consultants, instructors, and students.
Model Tax Convention On Income And On Capital Condensed Version 2014
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2014-08-20
Model Tax Convention On Income And On Capital Condensed Version 2014 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 2014-08-20 with categories.
The OECD Model Tax Convention provides the basis for the negotiation and interpretation of more than 3000 tax treaties that make up a network that co-ordinate the income and corporate tax systems of most countries with the objective of removing tax barriers to cross-border trade and investment.
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.
Yearbook On International Investment Law Policy 2013 2014
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Author : Andrea K. Bjorklund
language : en
Publisher: Oxford University Press
Release Date : 2015-07-31
Yearbook On International Investment Law Policy 2013 2014 written by Andrea K. Bjorklund and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-07-31 with Law categories.
International investment law today consists of a network of multifaceted, multilayered international treaties that, in one way or another, involve virtually every country of the world. The evolution of this network raises a host of issues regarding international investment law and policy, especially in the area of international investment disputes. The Yearbook on International Investment Law & Policy 2013-2014 monitors current developments in international investment law and policy, focusing on recent trends and issues in foreign direct investment (FDI). With contributions by leading experts in the field, this title provides timely, authoritative information on FDI that can be used by a wide audience, including practitioners, academics, researchers, and policy makers. The 2013-2014 Yearbook begins with trends in international investment and the activities of multinational enterprises, a review of trends and new approaches in international investment agreements for 2013-2014, and a review of international investment law and arbitration for 2013. This edition contains a sample of the research and ideas generated by the Investment Treaty Forum at the British Institute of International and Comparative Law--The Investment Treaty Forum brings together experts in international investment law to engage in high-level debate about salient topics in investment law. This edition covers many important topics, such as the principle of proportionality and the problem of indeterminacy in international investment treaties; proportionality, reasonableness and standards of review in investment treaty arbitration; and the role of investors' legitimate expectations in defense of investment treaty claims. The general articles included in this volume provide analysis of balancing investor protection and regulatory freedom in international investment law. The jurisprudential interaction between ICSID tribunals and the International Court of Justice are also discussed, along with inconsistencies in investor-state awards, the role of state interpretations; old and new ways for host states to defend against investment arbitrations, and approaches and analogies in the countermeasures defense in investor-state disputes. This volume explores the political economy of crises and the international law of necessity after the great recession. In addition to this are articles on minilateral treaty-making and bilateral investment treaties; investment promotion, agencies; the trend toward open contracting; and new regulations on foreign acquisitions of land in Brazil and Argentina. This volume concludes with the winning memorials from the 2013 FDI International Moot Competition.
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”.
The Law And Practice Of Trademark Transactions
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Author : Irene Calboli
language : en
Publisher: Edward Elgar Publishing
Release Date : 2016-02-26
The Law And Practice Of Trademark Transactions written by Irene Calboli 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 2016-02-26 with Law categories.
The Law and Practice of Trademark Transactions is a comprehensive analysis of the law governing trademark transactions in a variety of legal and business contexts, and from a range of jurisdictional and cross-border perspectives. After mapping out the international legal framework applicable to trademark transactions, the book provides an analysis of important strategic considerations, including: tax strategies; valuation; portfolio splitting; registration of security interests; choice-of-law clauses; trademark coexistence agreements, and dispute resolution mechanisms. Key features include: • A comprehensive overview of legal and policy-related issues • A blend of approaches underpinning strategic considerations with analytical rigour • Regional coverage of the key characteristics of trademark transactions in a range of jurisdictions • Authorship from renowned trademark experts Practitioners advising trademark owners, including trademark attorneys, will find this book to be an invaluable resource for their practice, particularly where cross-border issues arise. It will also be a key reference point for scholars working in the field.
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