Transfer Pricing And Developing Economies


Transfer Pricing And Developing Economies
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Transfer Pricing And Developing Economies


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.



Transfer Pricing And Developing Economies


Transfer Pricing And Developing Economies
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Author : Joel Cooper
language : en
Publisher: Directions in Development
Release Date : 2016

Transfer Pricing And Developing Economies written by Joel Cooper and has been published by Directions in Development this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016 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."



Transfer Pricing Developments Around The World 2020


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.



Transfer Pricing Developments Around The World 2019


Transfer Pricing Developments Around The World 2019
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-08-09

Transfer Pricing Developments Around The World 2019 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 2019-08-09 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 papers 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 Transfer Pricing and Intra-Group Services; Recent Developments on Transfer Pricing and Intra-Group Financing; Recent Developments on the Nexus Rules to Tax Business Profits at Source; and Recent Developments on Attribution of Profits to Digital Permanent Establishments. 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.



United Nations Practical Manual On Transfer Pricing For Developing Countries 2017


United Nations Practical Manual On Transfer Pricing For Developing Countries 2017
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Author : United Nations
language : en
Publisher:
Release Date : 2017

United Nations Practical Manual On Transfer Pricing For Developing Countries 2017 written by United Nations and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with Business & Economics categories.


The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.



Transfer Pricing Developments Around The World 2022


Transfer Pricing Developments Around The World 2022
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-10-11

Transfer Pricing Developments Around The World 2022 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 2022-10-11 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 a 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 Transfer Pricing in the Post-Covid-19 Era. Recent Developments on Transfer Pricing and Substance. Recent Developments on Transfer Pricing and Business Restructurings. Recent Developments on Transfer Pricing and New Technologies. The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, 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 efficient dialog and a coordinated approach to transfer pricing in the future.



Transfer Pricing Developments Around The World 2018


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.



United Nations Handbook On Selected Issues In Protecting The Tax Base Of Developing Countries


United Nations Handbook On Selected Issues In Protecting The Tax Base Of Developing Countries
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Author : United Nations Department of Economic and Social Affairs
language : en
Publisher: United Nations
Release Date : 2015-12-15

United Nations Handbook On Selected Issues In Protecting The Tax Base Of Developing Countries written by United Nations Department of Economic and Social Affairs and has been published by United Nations this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-12-15 with Political Science categories.


Taxation plays a critical role in promoting sustainable development and developing countries face significant challenges in mobilizing domestic resources. This publication analyses a number of topics which are of particular interest and relevance to developing countries in raising revenues and protecting the tax base. It aims at providing practical assistance to these countries in assessing and addressing the relevant issues in an effective way. Primary audiences are officials of national tax authorities and ministries of finance in developing countries, other professionals dealing with tax matters, the general public, media and universities.



Multinationals And Transfer Pricing


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.



Dealing Effectively With The Challenges Of Transfer Pricing


Dealing Effectively With The Challenges Of Transfer Pricing
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2012-01-18

Dealing Effectively With The Challenges Of Transfer Pricing 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 2012-01-18 with categories.


This report addresses the practical administration of transfer pricing programmes by tax administrations.