The Economics Of Transfer Pricing
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Transfer Pricing
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Author :
language : en
Publisher:
Release Date :
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 with Transfer pricing categories.
... analyzes the economics of transfer pricing, considers the viability of the arm's-length approach, and discusses the use of a company's internal data to assist in establishing and defending transfer prices.
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.
The Economies Of Transfer Pricing
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Author : Lorraine Eden
language : en
Publisher:
Release Date : 2019
The Economies Of Transfer Pricing written by Lorraine Eden and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with Transfer pricing categories.
Transfer Pricing And Multinational Enterprises
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 1979-06-01
Transfer Pricing And Multinational Enterprises 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 1979-06-01 with categories.
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.
The Economics Of Transfer Pricing
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Author : Lorraine Eden
language : en
Publisher:
Release Date : 2019
The Economics Of Transfer Pricing written by Lorraine Eden and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with Transfer pricing categories.
This authoritative single-volume collection offers the most influential papers relating to the economics of transfer pricing. The literature notably covers the topic in light of divisionalization, government regulations, bargaining models, market distortions and product characteristics as well as touching on the important subjects of empirical estimates of transfer price manipulation and transfer mispricing estimates. Accompanied by an original introduction by Lorraine Eden, one of the founders and a leading contributor to the field, this volume promises to be useful reading for doctoral students, faculty members and policy makers who wish to extend their knowledge on the economics of transfer pricing.
Transfer Pricing Developments Around The World 2020
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2020-09-28
Transfer Pricing Developments Around The World 2020 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 2020-09-28 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 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 the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union 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 academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.
Multinationals And Transfer Pricing
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Author : Alan M. Rugman
language : en
Publisher: Routledge
Release Date : 2017-02-03
Multinationals And Transfer Pricing written by Alan M. Rugman and has been published by Routledge this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-02-03 with Business & Economics categories.
One of the reasons for the success of multinational enterprises in their ability to create in their supranational organisations "internal markets" which eliminate the imperfections of external world markets caused by tariffs on trade, restrictions on the flow of capital, information costs and so on. The method multinationals use to create and sustain internal markets is transfer pricing. Multinationals use to their advantage the difference between nominal accounting and real transfers from their head offices to a subsidiary in different countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals’ use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.
Transfer Pricing And Corporate Taxation
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Author : Elizabeth King
language : en
Publisher: Springer Science & Business Media
Release Date : 2008-10-11
Transfer Pricing And Corporate Taxation written by Elizabeth King 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 2008-10-11 with Business & Economics categories.
National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.
Transfer Pricing
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Author : Fouad Sabry
language : en
Publisher: One Billion Knowledgeable
Release Date : 2024-03-28
Transfer Pricing written by Fouad Sabry and has been published by One Billion Knowledgeable this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-03-28 with Business & Economics categories.
What is Transfer Pricing Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm's length. The OECD and World Bank recommend intragroup pricing rules based on the arm's-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative practice. Countries with transfer pricing legislation generally follow the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in most respects, although their rules can differ on some important details. How you will benefit (I) Insights, and validations about the following topics: Chapter 1: Transfer pricing Chapter 2: Tax deduction Chapter 3: Capital gain Chapter 4: Tax treaty Chapter 5: Corporate tax Chapter 6: Indirect tax Chapter 7: Partnership taxation in the United States Chapter 8: Arm's length principle Chapter 9: Gross income Chapter 10: International taxation Chapter 11: Tax consolidation Chapter 12: Patent valuation Chapter 13: Optimal tax Chapter 14: Advance pricing agreement Chapter 15: Corporate tax in the United States Chapter 16: Foreign tax credit Chapter 17: Transactional net margin method Chapter 18: Transfer mispricing Chapter 19: Canada v GlaxoSmithKline Inc Chapter 20: Base erosion and profit shifting Chapter 21: Base erosion and profit shifting (OECD project) (II) Answering the public top questions about transfer pricing. (III) Real world examples for the usage of transfer pricing in many fields. Who this book is for Professionals, undergraduate and graduate students, enthusiasts, hobbyists, and those who want to go beyond basic knowledge or information for any kind of Transfer Pricing.
Transfer Pricing
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Author : Irving H. Plotkin
language : en
Publisher:
Release Date :
Transfer Pricing written by Irving H. Plotkin and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on with Transfer pricing categories.
...analyzes the economics of transfer pricing, considers the viability of the arm's-length approach, and discusses the use of a company's internal data to assist in establishing and defending transfer prices.