Resolving Transfer Pricing Disputes
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Transfer Pricing And Dispute Resolution
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Author : Anuschka Bakker
language : en
Publisher: IBFD
Release Date : 2011
Transfer Pricing And Dispute Resolution written by Anuschka Bakker and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Dispute resolution (Law). categories.
This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.
Resolving Transfer Pricing Disputes
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Author : Eduardo Baistrocchi
language : en
Publisher: Cambridge University Press
Release Date : 2012-12-06
Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-12-06 with Law categories.
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Strategic Approach To Transfer Pricing Disputes Through Mediation Under The Map
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Author : Leticia Cristofolini
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2025-07-17
Strategic Approach To Transfer Pricing Disputes Through Mediation Under The Map written by Leticia Cristofolini 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 2025-07-17 with Law categories.
Effective dispute resolution, efficiency, and legal certainty are crucial in the complex world of transfer pricing. This innovative book presents a structured framework for incorporating mediation into the Mutual Agreement Procedure (MAP), offering a solution for satisfactory, speedy, and fair settlements. In this context, the author analyzes the challenges of resolving transfer pricing disputes, assesses existing mechanisms, and demonstrates ways to overcome the MAP’s constraints and achieve better settlements for both taxpayers and tax administrations. Aspects of transfer pricing and dispute resolution covered include: transfer pricing risk management; compliance with diverse transfer pricing regulations across different jurisdictions; alignment with the arm’s length principle; critical evaluation of the MAP’s shortcomings; establishment of clear deadlines for MAP stages; elimination of upfront payment of challenged taxes; selection of mediators with expertise in transfer pricing; and provisions safeguarding confidentiality throughout the procedure. Based on these insights, the author advocates for key changes in domestic laws and policies of countries to enhance flexibility in navigating transfer pricing disputes in the most efficient, satisfactory, and cost-effective manner. This book presents a comprehensive and systematic framework, designed to benefit jurisdictions, taxpayers, and tax professionals seeking more certainty and a more transparent, simplified, and efficient approach to dispute resolution. Tax professionals, legal practitioners, policymakers, tax authorities, and multinational enterprises will all discover a transparent and inclusive dispute resolution framework that guarantees superior results and ensures more effective implementation of international tax standards while enabling states to collect their fair share of taxes within the evolving international tax landscape.
The Transfer Pricing Of Intangibles
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Author : Michelle Markham
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2005-01-01
The Transfer Pricing Of Intangibles 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 2005-01-01 with Law categories.
Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.
A Global Analysis Of Tax Treaty Disputes
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Author : Eduardo Baistrocchi
language : en
Publisher: Cambridge University Press
Release Date : 2017-08-17
A Global Analysis Of Tax Treaty Disputes written by Eduardo Baistrocchi and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-08-17 with Law categories.
This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Transfer Pricing And Developing Economies
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Author : Joel Cooper
language : en
Publisher: World Bank Publications
Release Date : 2017-01-05
Transfer Pricing And Developing Economies written by Joel Cooper and has been published by World Bank Publications this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-01-05 with Business & Economics categories.
Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program.Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.
Taxation Disputes And Resolution Mechanism
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Author : Dr. (Adv) Priyanka Shokeen
language : en
Publisher: Casa Editorial
Release Date :
Taxation Disputes And Resolution Mechanism written by Dr. (Adv) Priyanka Shokeen and has been published by Casa Editorial this book supported file pdf, txt, epub, kindle and other format this book has been release on with Business & Economics categories.
This book on Taxation Dispute Resolution Mechanism with Special Reference to International Trade explores the intricate legal and procedural frameworks governing tax-related conflicts in global commerce. It delves into the What is dispute and how it can effect any economy it also delves into intersection of tax law and international trade, analyzing the mechanisms designed to resolve disputes between multinational corporations and tax authorities. Key areas include bilateral and multilateral treaties, such as the OECD Model Tax Convention, and how they address tax evasion, double taxation, and transfer pricing issues. The book also examines arbitration and mediation as effective tools for resolving such disputes, comparing various countries' approaches and international organizations' roles in shaping dispute resolution frameworks. In the context of globalization, your book highlights the growing complexity of tax-related disagreements, emphasizing the need for streamlined processes to promote trade without compromising tax compliance. The work provides a critical analysis of case law, treaties, and dispute settlement mechanisms to guide practitioners, policymakers, and academics.
Transfer Pricing Developments Around The World 2018
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2018-08-21
Transfer Pricing Developments Around The World 2018 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 2018-08-21 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 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 seven topic-based papers prepared by international experts on transfer pricing. Greatly helping to define where the line should be drawn to distinguish genuine transfer pricing issues from other anti-avoidance measures, 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 documentation and country-by-country reporting; • recent developments on comparability analysis in transfer pricing; and • recent developments on the profit split method. The intense work of international organizations such as the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund, and other international organizations 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 an efficient dialogue and coordinated approach to transfer pricing in the future.
Tax Treaty Dispute Resolution
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Author : Rachna Matabudul
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2023-11-07
Tax Treaty Dispute Resolution written by Rachna Matabudul 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 2023-11-07 with Law categories.
Stakeholders in the international taxation community agree that existing dispute resolution processes are in serious need of improvement, and a global consensus must be achieved. This book offers a potential restructuring of the tax treaty dispute resolution system based on a comparative analysis of the dispute resolution mechanisms under tax treaties, as prescribed in the OECD and UN models, on the one hand, and the UN Law of the Sea Convention (LOSC) on the other. This comparative study is the first of its kind and is premised on certain key geopolitical similarities that underpin the international tax regime (ITR) and the law of the sea regime while taking into consideration the differences in the institutional context of both regimes. The author proposes a new tax treaty dispute resolution system based on the LOSC system for resolving multilateral tax disputes, focusing on the following: mapping of the institutional arrangements that make up the dispute resolution mechanisms to understand how each system works; comparative analysis of the patterns of interaction and outcomes generated across the two dispute resolution systems to identify relevant aspects of the LOSC system that may be adapted in the ITR to improve tax treaty dispute resolution; and analysis of the inclusivity levels across the decision-making structures under each system to identify specific consensus-building techniques that may facilitate the implementation of the new proposed tax treaty dispute resolution system and also enhance international cooperation across the ITR. The proposed restructuring of the tax treaty dispute resolution system expands the existing mutual agreement procedure and forms a comprehensive legal framework that aims to achieve a more effective, predictable and equitable resolution of multilateral tax disputes in the 21st-century ITR by striking a balance between countries’ right to tax sovereignty and the rule of law. Just as the design of the dispute resolution system under the LOSC paved the way for universal consensus of the Convention among almost 160 countries, the author’s new tax treaty dispute resolution system also offers a solid foundation for consensus-building towards a universal treaty in the ITR. Everyone concerned with international tax dispute resolution – whether policymaker, in-house counsel, national tax authority official, judge, tax lawyer or academic – will find the truly valuable analysis here, not elsewhere.
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.