Transfer Pricing And Customs Valuation

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Transfer Pricing And Customs Valuation

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Author : Anuschka Bakker
language : en
Publisher: IBFD
Release Date : 2009

Transfer Pricing And Customs Valuation 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 2009 with Customs appraisal categories.

This book discusses the intricate role of transfer pricing and customs value in international business environment. It examines the relationship between valuation for transfer pricing purposes and valuation for customs, and the significance of the relationship for multinational enterprises, tax authorities and customs administrations. The book begins by reviewing relevant international standards such as the OECD Guidelines and the GATT/WTO Customs Valuation Agreement. This is followed by a discussion of related issues such as VAT and administrative matters. Country chapters provide an overview of the applicable legislation and valuation methods, and case studies allow direct comparison between the practices of the different countries. The book concludes by summarizing the existing relationship between transfer pricing valuations and customs valuations, and by suggesting possible solutions towards a more integrated approach.

Customs Valuation And Transfer Pricing

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Author : Juan Martin Jovanovich
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24

Customs Valuation And Transfer Pricing written by Juan Martin Jovanovich 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 2016-04-24 with Law categories.

Issues of transfer pricing have come to the fore in both international tax and customs regimes. In particular, the problem of how to apply the two systems of valuation to the same transaction is of widespread concern. This well-known book, now in a fully updated second edition, is a problem-solving guide for professionals charged with valuating transactions in their client’s or company’s best interests. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, it offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized. Among other essential elements, the author discusses the following in depth: – the OECD Transfer Pricing Guidelines; – the GATT/WTO Customs Valuation Code (GVC) and other valuation rules in key jurisdictions and regional agreements; – the OECD and UN model tax conventions; – the arm’s length principle; – methods, both traditional and new, of determining whether the parties’ relationship in uenced the price; and – additions to and deductions from the customs value. This second edition discusses new developments in the eld, including a chapter on Commentary 23.1 and Case Study 14.1 of the Technical Committee on Customs Valuation of the World Customs Organization (WCO) – the rst international instruments linking transfer pricing and customs valuation. The book concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing year-end adjustments to transaction value would be consistent with Article 1 of the GVC. The book will continue to provide practitioners, customs administrations, and academics with a highly practical analysis of the intersection of transfer pricing and customs valuation. It will be welcomed by customs administrations charged with examining the acceptability of a transaction value xed between related parties and by multinational companies as a truly actionable tool they can use to optimize decision-making as it relates to transfer pricing and customs valuation in a “real world” setting.

A Handbook On The Wto Customs Valuation Agreement

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Author : Sheri Rosenow
language : en
Publisher: Cambridge University Press
Release Date : 2010-12-02

A Handbook On The Wto Customs Valuation Agreement written by Sheri Rosenow 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 2010-12-02 with Law categories.

This guide to the WTO Customs Valuation Agreement is based on the authors' experiences of teaching its finer points to customs officials and policy-makers around the world. Covering the methods of valuation and the provisions on enforcement, implementation and dispute settlement, the authors give practical examples, explain interpretative decisions of national and international customs bodies, and analyse the history of its negotiation. Written as a learning tool, it helps both new and experienced policy-makers, customs officials, importers and exporters to gain a deeper understanding of the Agreement's function and aims.

Customs Valuation And Transfer Pricing Is It Possible To Harmonize Customs And Tax Rules

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Author : Juan Jovanovich
language : en
Publisher: Springer
Release Date : 2002-10-30

Customs Valuation And Transfer Pricing Is It Possible To Harmonize Customs And Tax Rules written by Juan Jovanovich and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2002-10-30 with Business & Economics categories.

Although valuation is fundamental to both tax and customs liability in international transactions, values calculated by the two regimes can differ, often markedly, in situations where no clear rules of transfer pricing apply. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, Customs Valuation and Transfer Pricing offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized.Among the essential elements of this important thesis, the author discusses the following in depth: the OECD Transfer Pricing Guidelines; the GATT/WTO Valuation Code (GVC); the arm's length principle; methods, both traditional and new, of determining whether the parties' relationship influenced the price; and additions to and deductions from the customs value. The study concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing compensatory adjustments to transaction value would be consistent with Article 1 of the GVC.

Customs Valuation And Transfer Pricing Icc Proposals

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Author : J-M. Salva
language : en
Publisher:
Release Date : 2016

Customs Valuation And Transfer Pricing Icc Proposals written by J-M. Salva and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016 with categories.

The article studies the relationship between transfer pricing and customs valuation. The author explains two different approaches of transfer pricing, the first one adopted by tax agencies, based on the OECD Transfer Pricing Guidelines and the second adopted by customs agencies, based on the WTO Customs Valuation Agreement (CVA). From the business perspective, the divergence between the two taxation regimes is an obstacle to the liberalization of trade and inhibits international development for companies. On the other hand, the International Chamber of Commerce (ICC) believes that the WTO CVA and the use of the OECD Guidelines are enough to settle the issue of customs valuation and transfer pricing. However, ICC specifies that tax and customs approaches of intercompany transactions should converge to the same value. In this goal, ICC published a policy statement in 2012, which has been integrated in the WCO guidelines. This statement, based on the harmonization of the current rules, contains several additional options to derive customs value. The author states that the Union Customs Code does not contain any evolution from a transfer pricing perspective but contains some negatives changes regarding custom valuation. Also, the opportunity of the WCO Free Trade Agreement should be taken to move forward on this issue.

Transfer Pricing

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Author : Marc M. Levey
language : en
Publisher: CCH Incorporated
Release Date : 2010

Transfer Pricing written by Marc M. Levey and has been published by CCH Incorporated this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010 with Transfer pricing categories.

Transfer Pricing: Rules, Compliance and Controversy offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Throughout the book, the authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures.

Elgar Encyclopedia Of International Economic Law

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Author : Krista Nadakavukaren Schefer
language : en
Publisher:
Release Date : 2025-08-28

Elgar Encyclopedia Of International Economic Law written by Krista Nadakavukaren Schefer and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2025-08-28 with Law categories.

This revised and expanded Encyclopedia is the new benchmark and flagship reference work for the study of international economic law. A comprehensive resource, its pages present the breadth of the field in a real-world context. Organized thematically rather than alphabetically, the Encyclopedia includes four significant thematic sections: the foundations, architecture and principles of international economic law; regulatory framework; regulatory areas; and regulatory challenges. Including updated and new entries, traditional international economic law topics are now supplemented by coverage of critical perspectives and a broader range of newly developing areas such as taxation, sustainability, and digitalization. Concepts and rules of trade, investment, finance, competition, and international tax law are found alongside entries examining how international economic law impacts on environmental protection, labor standards, development, and human rights. Embedded within its own legal context, each concise entry presents an accessible and condensed understanding of what it means and why it is significant. Contributors offer insight into how institutions interact with each other and other legal systems, in addition to providing individual overviews of their history, structure, principles and procedures. Entries are followed by selected references suggesting directions for further study. Completely new to this edition is an entire section of extended entries on specific jurisdictions focusing on how these contribute to and engage with international economic law. These longer pieces describe the national legal frameworks responsible for developing international policies on trade investment, financial regulation, and tax, offering insight into how international rules actually work at the national level. Key Features: Concise, structured entries from top experts and new voices in the field Organised thematically, covering newly developing areas of international economic law Selected references for further study

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.

Transfer Pricing Methods

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Author : Robert Feinschreiber
language : en
Publisher: John Wiley & Sons
Release Date : 2004-03-01

Transfer Pricing Methods written by Robert Feinschreiber and has been published by John Wiley & Sons this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004-03-01 with Business & Economics categories.

Advanced praise for Transfer Pricing Methods "Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue." -Charles R. Goulding, Managing Director, Tax Cooper Industries, Inc. "It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses." -Vikram A. Gosain, JD, CPA, Director of Transfer Pricing General Electric Capital Corporation "This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants." -Joseph C. Mandarino, Partner Troutman Sanders, LLP "Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty." -Charles L. Crowley, Partner ITS/Customs and International Trade Practice, Ernst & Young, LLP "Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational." -Enrique MacGregor, Principal-in-Charge, Transfer Pricing Services Grant Thornton LLP "Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate." -Alan Getz, Vice President and General Manager, Tax Mitsui & Co., Inc. (U.S.A.) "Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner." -Per H. Hasenwinkle, National Practice Leader, Transfer Pricing BDO Seidman, LLP

Fundamentals Of Transfer Pricing

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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2025-05-19

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 2025-05-19 with Law categories.

Fundamentals of Transfer Pricing Volume 1: Principles and Practice Edited by Raffaele Petruzzi, Giammarco Cottani & Michael Lang Transfer pricing is one of the most important and complex topics in international taxation. Recognising its significance, most countries in the world have introduced transfer pricing rules in their domestic tax systems. This book, the first of a three-volume series, explains in a clear and simple manner the most important transfer pricing topics, with a collection of incisive and wide-ranging perspectives from representatives of academia, tax law practice, multinational companies, advisory groups, national tax authorities, and international organisations from all over the globe. The contributions collectively offer a comprehensive guide to the practical application of transfer pricing rules, covering various aspects as the following: introduction to transfer pricing; accurate delineation and recognition of actual transactions; transfer pricing methods; comparability analysis; transfer pricing audits and litigation; administrative approaches to preventing and resolving transfer pricing disputes; transfer pricing documentation; attribution of profits to permanent establishments; transfer pricing and specific transactions; use of new technologies in transfer pricing; and interplay between transfer pricing and other rules. This book delves into both foundational concepts and emerging trends in transfer pricing, providing readers with the tools to understand its dynamic application in real-world scenarios. By analysing examples, case studies, and the implications of recent judicial precedents, it bridges the gap between fundamental principles and practical implementations. The application of transfer pricing legislation remains one of the most challenging tasks for taxpayers and tax authorities around the world. With this comprehensive source of practical guidance, tax lawyers, in-house tax counsels, government officials, academics, advisory firms, and the business community worldwide will have all the support they need to move forward in tackling this complex aspect of the current tax environment.