The Oecd Transfer Pricing Guidelines And Value Creation
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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.
Transfer Pricing And Value Creation
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Author : Raffaele Petruzzi
language : en
Publisher:
Release Date : 2019
Transfer Pricing And Value Creation written by Raffaele Petruzzi and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019 with categories.
The Oecd Transfer Pricing Guidelines And Value Creation
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Author :
language : en
Publisher:
Release Date : 2024
The Oecd Transfer Pricing Guidelines And Value Creation written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024 with categories.
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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Author : OECD
language : en
Publisher: Org. for Economic Cooperation & Development
Release Date : 2015-10-19
Oecd G20 Base Erosion And Profit Shifting Project Aligning Transfer Pricing Outcomes With Value Creation Actions 8 10 2015 Final Reports written by OECD and has been published by Org. for Economic Cooperation & Development this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-10-19 with categories.
The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
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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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2015-10-05
Oecd G20 Base Erosion And Profit Shifting Project Aligning Transfer Pricing Outcomes With Value Creation Actions 8 10 2015 Final Reports 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 2015-10-05 with categories.
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Actions 8-10.
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 G20 Base Erosion And Profit Shifting Project Guidance On Transfer Pricing Aspects Of Intangibles
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2014-09-16
Oecd G20 Base Erosion And Profit Shifting Project Guidance On Transfer Pricing Aspects Of Intangibles 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 2014-09-16 with categories.
This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles.
Transfer Pricing And Intangibles
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2019-04-11
Transfer Pricing And Intangibles written by Michael Lang 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 2019-04-11 with Law categories.
Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2022
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2022-01-20
Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2022 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 2022-01-20 with categories.
In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.
Beps Action 8 10 Aligning Transfer Pricing Outcomes With Value Creation
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Author : B.W.A.M. Damsma
language : en
Publisher:
Release Date : 2017
Beps Action 8 10 Aligning Transfer Pricing Outcomes With Value Creation written by B.W.A.M. Damsma 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.
This article deals with BEPS Actions 8-10. In particular, it deals with the moving of intangibles within a group, shifting of risks and excessive allocation of capital to group entities and internal transactions. The main changes in the OECD Transfer Procing Guidelines are also considered.
