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Transfer Pricing Handbook


Transfer Pricing Handbook
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Transfer Pricing Handbook


Transfer Pricing Handbook
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Author : Robert Feinschreiber
language : en
Publisher: John Wiley & Sons
Release Date : 2012-08-03

Transfer Pricing Handbook 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 2012-08-03 with Business & Economics categories.


Learn OECD guidance on business taxation in multiple countries A business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying more in taxes that the share of profit it generates. The Organisation for Economic Co-operation and Development (OECD) seeks to reduce the risk of business taxation in multiple countries. Transfer Pricing Handbook explores how countries can apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. It is the ultimate comprehensive guide for companies doing business globally. Helps companies properly price their goods and services for global markets Provides defenses for transfer pricing audits Provides standards for creating comparables that multijurisdictional tax administrations will accept Guides documentation requirements and timing issues If you're doing business in more than one country, Transfer Pricing Handbook is a must-have, essential guide for simplifying OECD regulations for your global company.



Asia Pacific Transfer Pricing Handbook


Asia Pacific Transfer Pricing Handbook
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Author : Robert Feinschreiber
language : en
Publisher: John Wiley & Sons
Release Date : 2012-10-03

Asia Pacific Transfer Pricing Handbook 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 2012-10-03 with Business & Economics categories.


An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businesses A comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders. Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad. Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the law A complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad.



Transfer Pricing Handbook


Transfer Pricing Handbook
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Author : Robert Feinschreiber
language : en
Publisher: John Wiley & Sons
Release Date : 2001

Transfer Pricing Handbook 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 2001 with Business & Economics categories.


This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).



Transfer Pricing Handbook


Transfer Pricing Handbook
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Author : Robert Feinschreiber
language : en
Publisher: John Wiley & Sons
Release Date : 2001

Transfer Pricing Handbook 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 2001 with Business & Economics categories.


This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).



Transfer Pricing Handbook 2 Volume Set


Transfer Pricing Handbook 2 Volume Set
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Author : Robert Feinschreiber
language : en
Publisher: Wiley
Release Date : 2002-04-11

Transfer Pricing Handbook 2 Volume Set written by Robert Feinschreiber and has been published by Wiley this book supported file pdf, txt, epub, kindle and other format this book has been release on 2002-04-11 with Business & Economics categories.


This handbook provides a comprehensive analysis of the transfer pricing issues that affect taxpayers and tax collectors alike. It has a practical focus advising taxpayers about transfer pricing techniques and their consequences. * Provides non-tax transfer pricing guidance on such issues as imported merchandise, customs-related issues, and customs appraisement * Describes IRS penalties in detail * Describes various transfer pricing methodologies This core volume (ISBN 0471-406619) is supplemented annually. The 2002 Supplement includes updates to both Transfer Pricing 3e and Transfer Pricing International. It contains: * Two new chapters on Cost-Sharing Buy-Ins and Technology, Licensing, and Economic Issues in Transfer Pricing * Complete revisions to chapters on New Zealand, Singapore, Belgium, Czech Republic, Russia, and South Africa. (with updates to Germany chapter) * New Appendix containing information regarding Practice Note 7 This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).



Fundamentals Of Transfer Pricing


Fundamentals Of Transfer Pricing
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-01-03

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 2019-01-03 with Law categories.


Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint 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), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.



Transfer Pricing Methods


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



Transfer Pricing


Transfer Pricing
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Author : Alan Paisey
language : en
Publisher: Universal-Publishers
Release Date : 2012

Transfer Pricing written by Alan Paisey and has been published by Universal-Publishers this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012 with Business & Economics categories.


This book offers an introduction to transfer pricing with particular reference to China, for those who are looking for an overview that can be rapidly comprehended and who value diagrammatic images as a vehicle for learning. The subject is of importance both for Chinese and foreign personnel engaged in foreign company activity in China and for those who are similarly engaged in Chinese-owned companies already operating abroad, or which are to be extended to foreign locations.



The Transfer Pricing Of Intangibles


The Transfer Pricing Of Intangibles
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Author : Michelle Markham
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2005-01-01

The Transfer Pricing Of Intangibles written by Michelle Markham 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 2005-01-01 with Law categories.


Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.



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.