Download or read book ECJ Judgment in Hamamatsu Case an Abrupt End to Interaction Between Transfer Pricing and Customs Valuation written by M. Friedhoff and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The impact of intercompany transfer pricing (adjustments) on the customs value of goods is increasingly attracting attention, particularly since the remarkable judgment of the EU Court of Justice in the Hamamatsu case. The authors discuss the interaction between transfer pricing and customs valuation in a general sense, with specific consideration of the impact of the Hamamatsu judgment. They subsequently propose new statutory or other guidance for aligning the setting of transfer prices and customs values more closely, based inter alia on a comparative law study of the position in the United States and Canada.
Download or read book The Court of Justice of the European Union Judgment in the Hamamatsu Case Defending EU Customs Valuation Law from the transfer Pricing Folly in Customs Matters written by D. Rovetta and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The article examines the ECJ decision in Hamamatsu Photonics Deutschland (case C-529/16) concerning customs valuation, transfer pricing and flat-rate adjustment.
Download or read book The Interplay Between Transfer Pricing and Customs Valuation in Case of Retroactive Profit Adjustments the Position of the ECJ in the Case Hamamatsu Photonics Deutschland Gmbh C 529 16 written by E. De Angelis and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article discusses the position recently taken by the European Court of Justice (ECJ) regarding the impact on customs valuation of the goods of retroactive profit adjustments performed to bring the financial results of the tested party in line with arm's length results. The article considers issues such as the choice of customs valuation method in case of transfer pricing systems envisaging year-end adjustments, the impact of advance pricing agreements (APAs) on the customs value of the goods, the options available to taxpayers when navigating through the nuances of the interplay between transfer pricing and customs valuation methods.
Download or read book Customs Law in the European Union written by José Rijo and published by Kluwer Law International B.V.. This book was released on 2021-11-25 with total page 557 pages. Available in PDF, EPUB and Kindle. Book excerpt: The regulation of imports and exports by customs authorities profoundly affects the activity of economic operators in international trade. This is (one of) the first book(s) in English to critically assess the legal instruments of the European Union’s trade and customs policy—namely the Union Customs Code and its regulatory instruments—taking account of doctrinal contributions and the jurisprudential acquis of the Court of Justice of the European Union. With unparalleled guidance for the adoption of the best customs solutions for international trade operations, the book covers such crucial elements of relevant law and procedure as the following: submission of goods to customs; types of customs declaration; the EU’s harmonized commodity description and coding system; setting of import and export duties; evaluation of the customs value of goods; determination of tariff quotas or suspensions; collection and payment of duties; proof of origin of goods; preferential arrangements: FTAs and GSP; customs debt and guarantees; issues raised by under-evaluation and under-invoicing of goods and false certifications of the origin of goods; effect of unfair competition practices (dumping and trade defense); right to appeal customs authority decisions; storage; and taxation. The complexity of customs requirements and procedures imposes on businesses the necessity to become familiar with the intricate mechanisms deriving from customs law. This book will prove an indispensable tool for all companies involved with import/export to and from Europe. It will be welcomed worldwide by in-house counsel, purchasing and supply chain departments, customs brokers, logistic and forwarding operators, customs officers, and interested academics both in and outside the European Union.
Download or read book European Tax Law written by Martijn Schippers and published by Kluwer Law International B.V.. This book was released on 2022-01-22 with total page 435 pages. Available in PDF, EPUB and Kindle. Book excerpt: European Tax Law Seventh Edition Volume II Marie Lamensch, Madeleine Merkx, Martijn Schippers, Ilona van den Eijnde Marie Lamensch is Professor of taxation at the UCLouvain and the Free University of Brussels and a lawyer at the Brussels’ Bar. She is also a member of the VAT Expert Group of the European Commission. Madeleine Merkx is Professor of indirect taxes at Erasmus University Rotterdam and a partner at the Tax Research Center of BDO the Netherlands. Martijn Schippers is Assistant Professor in customs law and indirect taxation at the Erasmus School of Law, programme coordinator of EFS’ Post-Master in EU Customs Law and member of EY’s Global Trade & Customs team in the Netherlands. Ilona van den Eijnde is Academic Teacher in customs law and indirect taxation at the Erasmus School of Law and a lawyer at EY in Rotterdam, specialized in customs, environmental & lifestyle taxation. The seventh edition of this leading textbook brings its comprehensive and systematic survey of European Indirect Tax Law up to July 2021. With its critical discussion of the EU tax rules in force and of the relevant ECJ case law, it surpasses every other edition in its clarification and analysis of the EU regulatory framework applicable to indirect taxes. The in-depth coverage of this Volume II includes: The Union Customs legislation The harmonised Union VAT legislation The harmonised Union excise and environmental tax legislation The Union administrative cooperation regulatory framework applicable to indirect taxes. Volume I of this book covers general topics of EU law relevant for taxation and EU law on direct taxation. Ben J.M. Terra (University of Amsterdam, the Netherlands, and Lund University, Sweden) and Peter J. Wattel (University of Amsterdam) wrote the first six editions of this handbook
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 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 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 216 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 Model Tax Convention on Income and on Capital Condensed Version 2017 written by OECD and published by OECD Publishing. This book was released on 2017-12-18 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
Download or read book Fresh from the Farm 6pk written by Rigby and published by . This book was released on 2006 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development. This book was released on 1995 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt: Includes 1999 update. 1998 update in back.
Download or read book Yvain written by Chretien de Troyes and published by Yale University Press. This book was released on 1987-09-10 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: The twelfth-century French poet Chrétien de Troyes is a major figure in European literature. His courtly romances fathered the Arthurian tradition and influenced countless other poets in England as well as on the continent. Yet because of the difficulty of capturing his swift-moving style in translation, English-speaking audiences are largely unfamiliar with the pleasures of reading his poems. Now, for the first time, an experienced translator of medieval verse who is himself a poet provides a translation of Chrétien’s major poem, Yvain, in verse that fully and satisfyingly captures the movement, the sense, and the spirit of the Old French original. Yvain is a courtly romance with a moral tenor; it is ironic and sometimes bawdy; the poetry is crisp and vivid. In addition, the psychological and the socio-historical perceptions of the poem are of profound literary and historical importance, for it evokes the emotions and the values of a flourishing, vibrant medieval past.
Download or read book Kumba Africa written by Sampson Ejike Odum and published by iUniverse. This book was released on 2020-11-03 with total page 123 pages. Available in PDF, EPUB and Kindle. Book excerpt: ‘KUMBA AFRICA’, is a compilation of African Short Stories written as fiction by Sampson Ejike Odum, nostalgically taking our memory back several thousands of years ago in Africa, reminding us about our past heritage. It digs deep into the traditional life style of the Africans of old, their beliefs, their leadership, their courage, their culture, their wars, their defeat and their victories long before the emergence of the white man on the soil of Africa. As a talented writer of rich resource and superior creativity, armed with in-depth knowledge of different cultures and traditions in Africa, the Author throws light on the rich cultural heritage of the people of Africa when civilization was yet unknown to the people. The book reminds the readers that the Africans of old kept their pride and still enjoyed their own lives. They celebrated victories when wars were won, enjoyed their New yam festivals and villages engaged themselves in seasonal wrestling contest etc; Early morning during harmattan season, they gathered firewood and made fire inside their small huts to hit up their bodies from the chilling cold of the harmattan. That was the Africa of old we will always remember. In Africa today, the story have changed. The people now enjoy civilized cultures made possible by the influence of the white man through his scientific and technological process. Yet there are some uncivilized places in Africa whose people haven’t tested or felt the impact of civilization. These people still maintain their ancient traditions and culture. In everything, we believe that days when people paraded barefooted in Africa to the swarmp to tap palm wine and fetch firewood from there farms are almost fading away. The huts are now gradually been replaced with houses built of blocks and beautiful roofs. Thanks to modern civilization. Donkeys and camels are no longer used for carrying heavy loads for merchants. They are now been replaced by heavy trucks and lorries. African traditional methods of healing are now been substituted by hospitals. In all these, I will always love and remember Africa, the home of my birth and must respect her cultures and traditions as an AFRICAN AUTHOR.
Download or read book Model Tax Convention on Income and on Capital 2017 Full Version written by OECD and published by OECD Publishing. This book was released on 2019-04-25 with total page 2624 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
Download or read book EU Equality Law written by Elise Muir and published by Oxford University Press. This book was released on 2018-11-08 with total page 412 pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Union is a supranational organisation with a set of circumscribed powers. Although these powers do not include an all-encompassing fundamental rights' mandate, today's existential challenges - from economic to refugee crisis, via concerns for compliance with the rule of law in some of its Member States - increase the pressure on the EU to develop tools for protection and promotion of such rights. One way of addressing the tension between the lack of a general mandate and vivid calls for protection is for the EU to focus on selected fundamental rights which it has competence to regulate. One such example is EU law on the fundamental right to equal treatment that has blossomed since the late 1990s. In developing selected fundamental right policies that can be imposed on domestic actors, as EU law does, supranational intervention needs to be carefully tailored to the plural landscape where they are intended to flourish. This monograph calls for a nuanced use of the infrastructure of EU law to convey shared values at domestic level across Europe.
Download or read book Harmonization of Accounting Standards written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications and Information Centre. This book was released on 1986 with total page 160 pages. Available in PDF, EPUB and Kindle. Book excerpt: The main features of standard-setting; Promoting international harmonization of accounting standards the role of intergovernmental organisations; Institution and substantive problems for harmonization ...
Download or read book Financial Reporting and Global Capital Markets written by Kees Camfferman and published by OUP Oxford. This book was released on 2007-03-08 with total page 702 pages. Available in PDF, EPUB and Kindle. Book excerpt: A detailed and scholarly historical study of the International Accounting Standards Committee (IASC), which prepared the way for the International Accounting Standards Board (IASB). The IASB holds the dominant influence over the financial reporting of thousands of listed companies in the European Union as well as in many other countries.
