Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations

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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 Guidelines For Multinational Enterprises And Tax Administrations Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-07-31

Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 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 2017-07-31 with categories.

Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2010-08-16

Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010 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 2010-08-16 with categories.

The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, the valuation, for tax purposes, of cross-border transactions between associated enterprises.

Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-07-31

Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 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 2017-07-31 with categories.

Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2009

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2009-08-18

Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2009 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 2009-08-18 with categories.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.

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.

Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2001 Travel Version

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2001-06-26

Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2001 Travel Version 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 2001-06-26 with categories.

The 2001 edition of Transfer Pricing Guidelines was substantially revised in July 2010. See the current edition. This compact version of Transfer Pricing Guidelines provides the complete and current text of the OECD pricing guidelines accepted by ...

Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations Set Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations Binder 1999 Update

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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 1999-11-12

Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations Set Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations Binder 1999 Update 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 1999-11-12 with categories.

Transfer Pricing Aspects Of Intra Group Financing

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Author : Raffaele Petruzzi
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2013-10-20

Transfer Pricing Aspects Of Intra Group Financing written by Raffaele Petruzzi 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 2013-10-20 with Law categories.

For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.

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.