Download or read book Transfer Pricing and Customs Valuation written by Anuschka Bakker and published by IBFD. This book was released on 2009 with total page 695 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book A Handbook on the WTO Customs Valuation Agreement written by Sheri Rosenow and published by Cambridge University Press. This book was released on 2010-12-02 with total page 287 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Transfer Pricing written by Marc M. Levey and published by CCH Incorporated. This book was released on 2010 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by . This book was released on 2019 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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. In analysing the 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.

Download or read book Transfer Pricing Methods written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2004-03-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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

Download or read book Intangibles in the World of Transfer Pricing written by Björn Heidecke and published by Springer. This book was released on 2021-03-10 with total page 725 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intangible assets are becoming increasingly important as value drivers for multinational companies. It is a strategic question how to allocate intangibles within the multinational corporation. It needs to be defined by whom and under which conditions they can be utilized. Typical IP migration models such as licensing, joint development and transferring are becoming a focal point within tax audits across the globe. Hence,defining an intangibles system that fulfils the tax requirements is of utmost strategic importance for multinational corporations. A central question is how to value intangibles in line with the arm’s length principle as is required internationally for transfer pricing purposes. Edited by leading transfer pricing and valuation experts in Europe, this comprehensive book offers practitioners an effective road map for identifying, valuing and implementing intangibles for transfer pricing purposes under consideration of both the OECD and local perspectives. It is therefore a must-have book for transfer pricing and valuation practitioners on all levels of experience. The book starts with an introduction to the role of intangibles in the world of transfer pricing including typical intangibles migration models. It describes common intangible assets across all types of industries, including e.g. automotive, consumer goods and software.Using several numerical examples, the book then covers state-of-the-art valuation methods including how to apply these methods in practice in a way consistent with the OECD Transfer Pricing Guidelines. The different country chapters written by local experts provide country-specific guidance on the legal framework concerning intangible assets from a transfer pricing and valuation perspective. Finally, the book covers practical advice on the implementation of an intangible assets system. This book offers invaluable guidance to practitioners seeking tools to apply the arm’s length principle in the world of intangibles.

Download or read book The Future of the Profit Split Method written by Gabriella Cappelleri and published by Kluwer Law International B.V.. This book was released on 2020-11-23 with total page 341 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Future of the Profit Split Method Edited by Robert Danon, Guglielmo Maisto, Vikram Chand & Gabriella Cappelleri Among the various transfer pricing methods, the profit split method (PSM) is under the spotlight after the OECD’s Base Erosion and Profit Shifting (BEPS) project. However, both expert analysis and experience indicate that this method is not straightforward either for taxpayers to apply or for tax administrations to evaluate. In this thorough and detailed commentary – the first book to analyse this increasingly adopted transfer pricing method – notable scholars and practitioners working in the international tax community express their views on the method, answering some unresolved questions and highlighting issues that are still open and pending, especially in light of the digitalization of the economy. Crucial issues covered by the contributors include the following: choice of the appropriate splitting factors, their relative weights, and valuation of the contributions; uncertainties and outcomes potentially not aligned with the arm’s-length standard; possible role of assessments made by the European Commission on State aid; nexus with the work done by the EU Joint Transfer Pricing Forum; impact of profit split on indirect taxes (VAT/customs tax/excise tax); and application to digital business models and, in general, to the digitalized economy. Moreover, relevant experience of applying this method in France, Germany, Italy, Spain, Switzerland, the United Kingdom, and the United States is provided. A concluding chapter also deals with selected industry experiences. Due to a high level of uncertainty in alignment with international guidance in the application of the PSM – and to the underdeveloped nature of current literature on the subject – there is a need for this book because both tax administrations and taxpayers, going forward, will apply the PSM extensively. The book is highly relevant for policymakers, tax administrations, practitioners and academics engaged in the areas of international taxation, transfer pricing and tax policy.

Download or read book Introduction to Transfer Pricing written by Jerome Monsenego and published by . This book was released on 2013-01-01 with total page 163 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.

Download or read book Business Valuation and Federal Taxes written by David Laro and published by John Wiley & Sons. This book was released on 2011-05-03 with total page 532 pages. Available in PDF, EPUB and Kindle. Book excerpt: Business Valuation and Federal Taxes Procedure, Law, and Perspective SECOND EDITION Combining the expert knowledge of Senior Judge David Laro and Shannon Pratt, Business Valuation and Federal Taxes, Second Edition presents the authors' decades of experience, with advice on everything practitioners need to know about the relationship between federal taxes and valuation, and specifically valuations relating to business interests. This reference features indepth examinations of numerous topics that are particularly important to practitioners and explores a broad understanding of the basic knowledge needed to appreciate business valuation. Valuators, CPAs consulting on valuations, attorneys, corporate development officers, and intermediaries on business valuation will benefit from insightful discussions on topics ranging from general definitions to valuing complex business interests, as well as new discussions of: Personal versus enterprise goodwill New materials on transfer pricing and customs valuations and how recent markets have affected both the income and market approaches Coverage of FAS 157 and the many changes to penalties and sanctions affecting both taxpayers and appraisers Several important new court cases Coverage is also included on standards of business valuation, IRS positions, burden of proof in valuation controversies, questions to ask business valuation experts, economic and industry analysis, and tax-affecting passthrough entities. Complete with a full overview of the laws, procedures, and approaches related to business valuation, this invaluable reference is a wellspring of vital information on valuation approaches, techniques, finance-related issues, burden of proof, standards, choice of entity, and much more.

Download or read book Customs Modernization Handbook written by Luc De Wulf and published by World Bank Publications. This book was released on 2005-01-03 with total page 356 pages. Available in PDF, EPUB and Kindle. Book excerpt: Trade integration contributes substantially to economic development and poverty alleviation. In recent years much progress was made to liberalize the trade regime, but customs procedures are often still complex, costly and non-transparent. This situation leads to misallocation of resources. 'Customs Modernization Handbook' provides an overview of the key elements of a successful customs modernization strategy and draws lessons from a number of successful customs reforms as well as from customs reform projects that have been undertaken by the World Bank. It describes a number of key import procedures, that have proved particularly troublesome for customs administrations and traders, and provides practical guidelines to enhance their efficiency. The Handbook also reviews the appropriate legal framework for customs operations as well as strategies to combat corruption.

Download or read book Transfer Pricing in China written by Chris Devonshire-Ellis and published by Springer Science & Business Media. This book was released on 2011-05-18 with total page 93 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Guide is a detailed overview of all aspects of transfer pricing in China. Produced in association with Transfer Pricing Associates, a specialist global transfer pricing firm, this is an essential work for any businessman trading with or conducting business in China. The book deals with all aspects of transfer pricing from a practical perspective, from designing and implementing a transfer pricing system, to managing China compliance and preparing for an audit.

Download or read book Customs Valuation and Transfer Pricing Is It Possible to Harmonize Customs and Tax Rules written by Juan Jovanovich and published by Springer. This book was released on 2002-10-30 with total page 168 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Customs Valuation and Transfer Pricing written by Juan Martin Jovanovich and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 323 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Transfer Pricing and Developing Economies written by Joel Cooper and published by World Bank Publications. This book was released on 2017-01-05 with total page 275 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book The Economics of Transfer Pricing written by Lorraine Eden and published by . This book was released on 2019 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This authoritative single-volume collection offers the most influential papers relating to the economics of transfer pricing. The literature notably covers the topic in light of divisionalization, government regulations, bargaining models, market distortions and product characteristics as well as touching on the important subjects of empirical estimates of transfer price manipulation and transfer mispricing estimates. Accompanied by an original introduction by Lorraine Eden, one of the founders and a leading contributor to the field, this volume promises to be useful reading for doctoral students, faculty members and policy makers who wish to extend their knowledge on the economics of transfer pricing.

Download or read book Importing Into the United States written by U. S. Customs and Border Protection and published by . This book was released on 2015-10-12 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains process of importing goods into the U.S., including informed compliance, invoices, duty assessments, classification and value, marking requirements, etc.

Download or read book United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 written by United Nations and published by . This book was released on 2017 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.