Download or read book Decoding Transfer Pricing for Selling Functions written by Rahul K Mitra and published by . This book was released on 2020-08-25 with total page 111 pages. Available in PDF, EPUB and Kindle. Book excerpt: Are some of the theories of OECD and UN around marketing intangibles sacrosanct? The same have been countered through qualitative and quantitative arguments. Quantitative arguments are based upon real life scenarios, with reference to statistical analyses on selected empirical data. Genesis of litigation around marketing intangibles analysed, along with solutions. Concept of royalties for licensed manufacturers explained in the context of regulatory regime of India. Practical solutions provided on harmonisation of transfer pricing and customs duty regulations in complex cases. Concept of attribution of profits to dependent agency permanent establishments explained, with reference to Berry Ratio. Foreword by Dr. Raffalle Dr. Raffaele Petruzzi & Dr. Alfred Storck Professors of Vienna University of Economics and Business

Download or read book Fundamentals of Transfer Pricing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2022-06-20 with total page 549 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing’s interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.

Download or read book Transfer Pricing and Financing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 261 pages. Available in PDF, EPUB and Kindle. Book excerpt: In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions: loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law. Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.

Download or read book U S Transfer Pricing Sourcebook written by Amanda Johnson and published by WorldTrade Executive, Inc.. This book was released on 2005-03 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: U.S. TRANSFER PRICING SOURCEBOOK is a single-volume report designed to advise international finance professionals on the cutting edge tools and techniques being developed and applied by leading consultants. This sourcebook provides strategies on Intercompany Sales, Intercompany Service transactions, Cross-Border licensing, and Cost Sharing agreements.

Download or read book Transfer Pricing and Intangibles written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2019-04-11 with total page 141 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.

Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2021-06-18 with total page 484 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.

Download or read book Decoding the U S Corporate Tax written by Daniel N. Shaviro and published by The Urban Insitute. This book was released on 2009 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The corporate tax could soon be headed in new directions," Dan Shaviro writes in Decoding the U.S. Corporate Tax, wherein he assesses the threats to America's corporate tax code and challenges conventional wisdom on the best avenues for reform. Shaviro dissects the vagaries of the law, lays out the fundamental policy issues, and considers the road ahead. As rising globalization, capital mobility, financial innovation, and political polarization combine to destabilize tax policy and government revenue, Shaviro maps the path to fair, revenue-generating reform.

Download or read book Transfer Pricing in Action written by Aydin Hayri and published by Kluwer Law International. This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an overview of the abstract theory of transfer pricing and its everyday practice. It is an extended hypothetical case history, presented in narrative style illustrated with graphics. It gives details of transfer pricing planning and how the process engages and affects the ambitions, insights, and interactions of the group of business people and advisors involved. The book contains the following chapters: (1) MSell - a fast growth company considers corporate taxation; (2) Big tax proposal, rejected; (3) The inevitable growing pains, and state tax planning ; (4) Going international, the Canadian expansion; (5) Further expansion: the United Kingdom and greater Europe; (6) The European distributors and a surprising development, or two; (7) Services transactions: US headquarter and support services for Europe; (8) Intangibles licensing transaction, with gusto; (9) Intra-European structuring; (10) Sourcing; (11) Branding, and a new CEO; (12) Planning for a new global business model; (13) Designing and implementing the new global business model; (14) A (rather unpleasant) Thanksgiving surprise; and a timeline figure.

Download or read book Transfer Pricing Handbook written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2001 with total page 1040 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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).

Download or read book Practical Guide to U S Transfer Pricing written by Robert T. Cole and published by Aspen Publishers. This book was released on 1999 with total page 1302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.

Download or read book The Fundamentals of U S Transfer Pricing written by Steve C. Wrappe and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Dual Transfer Pricing with Internal and External Trade written by Edward G. Johnson and published by . This book was released on 2017 with total page 33 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines a transfer pricing problem between two divisions of a decentralized firm. The selling division is privately informed about its own costs and produces a good that is sold both externally in an intermediate market and internally within the firm. Unlike most previous work, we focus on dual transfer pricing systems that allow the selling division to be credited for an amount that differs from the amount charged to the buying division. We identify conditions under which efficient decentralized trade and external price setting incentives can be provided with a properly chosen set of dual transfer prices that do not rely on direct communication. Instead, the optimal dual transfer prices will depend only on public information about the market price charged by the upstream division in the external market, which indirectly communicates information about production costs to the downstream division. For a variety of well-known demand functions, the optimal transfer prices will be linear functions of the market price. Our main results hold when the upstream division faces multiple internal buyers or faces a binding capacity constraint.

Download or read book The Transfer Pricing Law Review written by Steve Edge and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Decoding GST written by M. Sathya Kumar and published by Notion Press. This book was released on 2017-12-18 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Goods and Services Tax, which subsumes almost all indirect taxes to integrate the country into a single market, is the biggest tax reform that has been undertaken since independence. The vision behind the introduction of the GST is not only to get rid of the complexities of the indirect taxes that prevailed earlier but also to bring about ease in doing business. The book has been written in such a manner that it will help professionals gain a better understanding of the compliances under the newly introduced GST Law. It is a very useful reference for professionals, practitioners, corporate parties, and regulators as all the new provisions have been explained in a simple manner. It will be particularly helpful for mid- and small-sized businesses that may not have adequate access to the GST knowledge base.

Download or read book Strategy written by Stewart R Clegg and published by SAGE. This book was released on 2022-10-26 with total page 671 pages. Available in PDF, EPUB and Kindle. Book excerpt: Written by an expert team and praised for its refreshing approach, this essential text offers a critical, holistic understanding of strategy theory and practice. The fourth edition has been fully updated to include: • Coverage of contemporary issues including the Covid-19 pandemic, climate change and digitalization • Topical and engaging case studies such as Disney’s Strategy and Covid-19, Netflix Versus Amazon: Dynamic Capabilities for Global Success, and PS5, Xbox and BMW: Chips and Supply Chains • A wealth of new examples of strategy in practice from world-renowned organisations such as Google, Uniqlo, Tesla, IKEA, and Airbnb Suitable for both undergraduate and postgraduate study, Strategy: Theory and Practice encourages readers to engage critically with the internal and external factors that shape strategy in the real world. A selection of tried and tested online resources, including a teaching guide, PowerPoints, an online case study bank and test bank of questions have been developed to support lecturers using the book in their teaching. Stewart Clegg is Professor at the University of Sydney, Emeritus Professor at the University of Technology Sydney, and Visiting Professor at the University of Stavanger, University of Johannesburg, and Nova School of Business and Economics. Christos Pitelis is Head of Department of International Business and Professor of International Business and Sustainable Competitiveness at the University of Leeds, and Life Fellow at Queens’ College, University of Cambridge. Jochen Schweitzer is an Associate Professor at the University of Technology Sydney. Andrea Whittle is Professor of Management at Newcastle University Business School.

Download or read book Decoding the Metaverse written by Chris Duffey and published by Kogan Page Publishers. This book was released on 2023-02-03 with total page 369 pages. Available in PDF, EPUB and Kindle. Book excerpt: Discover the profitable business opportunities within the metaverse and learn how you can and why you should get your company involved today. In Decoding the Metaverse, Creative Cloud strategist and Web3 expert Chris Duffey establishes a roadmap for entry to the metaverse. Written to help businesses get a handle on a complex new business opportunity, the book begins by explaining how previous iterations of the internet led to the creation of immersive digital technology with Web3 before detailing the building blocks of the metaverse. The book takes readers through the future of digital spaces, offering insight into immersive experiences, customer engagement, product-led growth and profitability. The chapters focus on the building blocks of the metaverse, including NFTs, blockchain, tokenomics, gaming and virtual real estate. Each chapter is paired with a corresponding case study from well-known brands currently working in the metaverse. Decoding the Metaverse ends with guiding principles about the ethical ramifications of immersive experiences and digital governance. Throughout Decoding the Metaverse, Duffey highlights the importance of reaching customers through shared immersive experiences. Showcasing the potential impact of working with Web3, he explains how companies can use these opportunities to further their reach and grow their revenue. Readers will step away from the book eager to get their companies involved today.

Download or read book InfoWorld written by and published by . This book was released on 1996-03-25 with total page 122 pages. Available in PDF, EPUB and Kindle. Book excerpt: InfoWorld is targeted to Senior IT professionals. Content is segmented into Channels and Topic Centers. InfoWorld also celebrates people, companies, and projects.