transfer pricing answer book 2016

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Transfer Pricing Answer

Author : David B. Blair
ISBN : 140242616X
Genre : Law
File Size : 69. 81 MB
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The phenomena of increasingly global business enterprises with valuable intangible property expose companies to transfer pricing enforcement by different countries around the world. Many of these countries are increasingly aggressive in enforcing their local transfer pricing rules, as they attempt to protect their tax revenue base. To avoid double taxation of the same income in this environment, companies often are required to deal with the highly specialized, bilateral treaty-based competent authority process developed to prevent double taxation at a time when trade mainly involved only two established countries. Even more challenging today, companies and tax authorities increasingly are faced with the potential for multiple taxation of the same income, as supply chains cross many borders and as the tax authorities of emerging countries become players in the global taxation process, and the resulting stresses, strains, and limitations of the bilateral treaty-based competent authority process have become more apparent. In light of the high-dollar risks presented by the increased enforcement efforts of tax authorities worldwide, the complexity of the ever-changing, inherently uncertain transfer pricing standards, and the continually evolving business models of businesses adapting to the constantly changing global economy, companies need practical guidance to permit them to develop and defend their transfer pricing strategies. Transfer Pricing Answer Book 2016 gives companies such guidance by discussing all aspects of transfer pricing, from initially planning a transfer pricing strategy, to alternative ways to defend the strategy from attack by two or more tax authorities, to resolving a case before competent authorities, to bringing a transfer pricing case to court. The book s non-technical discussion is presented in a question and answer format that will appeal to readers regardless of their prior level of experience or familiarity with taxes in general and transfer pricing in particular. Transfer Pricing Answer Book 2016 is an invaluable resource for company executives and their advisors who are seeking to better understand this important area of tax law that has become such an important economic facet of so many businesses."

Transfer Pricing Methods

Author : Robert Feinschreiber
ISBN : 9780471651239
Genre : Business & Economics
File Size : 82. 35 MB
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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 Handbook

Author : Robert Feinschreiber
ISBN : 9781118376560
Genre : Business & Economics
File Size : 24. 51 MB
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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.

Transfer Pricing In A Post Beps World

Author : Michael Lang
ISBN : 9041167102
Genre : Law
File Size : 49. 18 MB
Format : PDF
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EUCOTAX Series on European Taxation Volume 50 The OECD s Base Erosion and Profit Shifting (BEPS) project promises to make effective inroads into the much criticized corporate tax strategy known as aggressive transfer pricing, whereby the profitability of subsidiaries in different jurisdictions is managed via mispricing with the intent of minimizing the corporation s overall tax burden. Although the OECD BEPS project is an ongoing endeavor, its accomplishments to date and developing trends are discernible. This book, including contributions by outstanding and renowned transfer pricing experts both from practice and academia, analyses these trends, and proposes reforms which would ensure that transfer pricing outcomes are better aligned with economic activities and value creation, which achieves a more equitable distribution of profits among different countries. Each chapter is dedicated to specific sections of the OECD s BEPS Action Plan. Among the topics and issues covered are the following: arm s length principle and its ongoing development; allocation of risk and recharacterization; intangibles (both license model and cost contribution arrangements); interest deductions and intra-group financing; low value-adding services; commissionaire arrangements and low-risk distributors; attribution of profits to permanent establishments; documentation requirements (including Country-by-Country Reporting). Within these topics, measures to identify the commercial and financial relationships inside multinational enterprises, to accurately delineate actual transactions, as well as guidance on defining risk and its allocation among entities of a multinational enterprise are discussed. The book is based on papers presented and discussed at the first Global Transfer Pricing Conference hosted in February 2016 by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business). The most up-to-date and thorough consideration of transfer pricing yet published, this book will prove invaluable for all parties currently facing questions related to transfer pricing in a post-BEPS world, especially those in charge of finding an ideal answer to them: academics, practitioners (including in-house and advisory counsel), international organizations, CEOs and CFOs of multinational enterprises, and government officials who are tax and transfer pricing experts. "

Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2017

Author : OECD
ISBN : 9789264265127
Genre :
File Size : 44. 53 MB
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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 Developments Around The World 2017

Author : Michael Lang
ISBN : 9041183752
Genre : Law
File Size : 37. 19 MB
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Transfer Pricing Developments Around the World 2017 presents and analyzes relevant developments around the world in transfer pricing. Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to grow worldwide at every level of government and international policy, with far-reaching impact on countries' legislations, administrative guidelines, and jurisprudence. 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 by seventeen renowned international experts on transfer pricing. What's in this book: This book helps in defining the line that should be drawn to distinguish genuine transfer pricing issues from other anti-avoidance measures and covers topics such as the following: Global Transfer Pricing Developments Transfer Pricing Developments in the European Union (including EU Joint Transfer Pricing Forum) Transfer Pricing Developments in the United States Transfer Pricing Developments at the United Nations Recent Developments on Transfer Pricing and Intra-group Financing Recent Developments on the Profit Split Method Recent Developments on Attribution of Profits to Dependent Agent Permanent Establishments Recent Developments on a Toolkit for Developing Countries The intense work of international organizations, such as OECD, the UN, the EU, the World Customs Organization, the World Bank, the International Monetary Fund, is thoroughly analyzed in this book. How this will help you: As the first in-depth, issue-by-issue analysis of the current state of developments in transfer pricing, this book offers solutions to complex transfer pricing issues raised. 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.

Transfer Pricing Aspects Of Inta Group Financing

Author : Raffaele Petruzzi
ISBN : 9041167323
Genre :
File Size : 88. 4 MB
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EUCOTAX Series on European Taxation Volume 47 Transfer Pricing Aspects of Intra-Group Financing provides one of the first in-depth analyses of the current worldwide working of transfer pricing in intra-group financing, and its resonance in law. For corporate managers, maximization of profits and market value of the company are prime objectives. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally because of the very attractive tax advantages obtainable. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This book presents solutions to issues that are related to transfer pricing and intra-group financing, by combining an academic and a practical approach. This important book presents the relevant issues related to loans, financial guarantees, and cash pooling and analyses an innovative possible approach to these issues. The book also 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. What's in this book: Comparing tax measures implemented in corporate tax law systems of forty countries, this study investigates aspects such as: 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. How this will help you: 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 the OECD Member States and their national courts is of great practical value in corporate decision-making.

Guide To International Transfer Pricing

Author : Duff & Phelps
ISBN : 9041161244
Genre : International business enterprises
File Size : 59. 4 MB
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The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide's relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.

Management Control Systems

Author : CTI Reviews
ISBN : 9781467238045
Genre : Education
File Size : 57. 60 MB
Format : PDF
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Facts101 is your complete guide to Management Control Systems. In this book, you will learn topics such as Behavior in Organizations, Responsibility Centers: Revenue and Expense Centers, Profit Centers, and Transfer Pricing plus much more. With key features such as key terms, people and places, Facts101 gives you all the information you need to prepare for your next exam. Our practice tests are specific to the textbook and we have designed tools to make the most of your limited study time.

Oecd Transfer Pricing Guidelines For Multinational Enterprises And Tax Administrations 2010

Author : OECD
ISBN : 9789264090187
Genre :
File Size : 86. 32 MB
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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.

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