Download or read book Intrafirm Trade and Global Transfer Pricing Regulations written by Roger Y. W. Tang and published by Praeger. This book was released on 1997-07-16 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is the most important issue in international taxation today, but transfer pricing regulations for the United States and its major trading partners have changed significantly over the past decade. Professor Tang explains these changes and their impact on trade among multinational companies. In doing so he covers not only changes in U.S. regulations and their effects on multinational companies, but also the changes that have taken place in Canada, Mexico, China, Japan, the United Kingdom, Germany, France, the OECD, and elsewhere, and their impact on U.S. business. Also discussed in detail are the advance pricing agreements (APA) programs of the United States and Canada; a new paradigm for resolving a variety of issues that have arisen recently in intrafirm trade and transfer pricing; and, for business executives, an approach for managing a corporate transfer pricing system. The book is an essential reading for professionals and their colleagues in the academic community.
Download or read book Transfer Pricing Intrafirm Trade and the BLS International Price Program written by Lorraine Eden and published by CreateSpace. This book was released on 2013-07-31 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: Most governments keep balance of payments statistics on exports and imports, by value, andconstruct international prices indexes in order to deflate these statistics. How can intrafirm trade(IFT), trade between related parties such as multinational enterprises (MNEs), bias theconstruction of these international price indexes? Economists have known for many years thatthe prices set by MNEs for intrafirm transfers -- transfer prices --- are normally not the prices that would be negotiated between arm's length parties (Diewert 1985, Eden 1985, Horst 1971).Does transfer pricing bias the export and import price indexes in any predictable fashion? Iffirms manipulate transfer prices to avoid taxes or tariffs, what is the appropriate transfer price touse in constructing export and import price indexes, in theory and in practice? These issues are important because related party trade is huge, representing half of US imports and one-third of US exports, and perhaps a third of worldwide merchandise trade flows.
Download or read book Anti Tax Avoidance Rules and International Trade written by Bodo Knoll and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over recent decades, countries around the world have introduced transfer pricing regulations to constrain tax-motivated strategic mis-pricing of intra-firm trade. While the literature has paid some attention to studying the effectiveness of the provisions in limiting mis-pricing behavior, work on potential real consequences of the rules is scarce. In this paper, we show that transfer pricing regulations distort the trading behavior of MNEs. Drawing on rich administrative firm-level trade data from Denmark, our findings document that tighter transfer price rules reduce firms' propensity to engage in intra-firm trade on affected routes. There is no indication for intra-firm trade responses at the intensive margin. We also find no changes in the real economic activity of treated firms in Denmark.
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 Intrafirm Trade and Global Transfer Pricing Regulations written by Roger Y. W. Tang and published by Praeger. This book was released on 1997-07-16 with total page 296 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is the most important issue in international taxation today, but transfer pricing regulations for the United States and its major trading partners have changed significantly over the past decade. Professor Tang explains these changes and their impact on trade among multinational companies. In doing so he covers not only changes in U.S. regulations and their effects on multinational companies, but also the changes that have taken place in Canada, Mexico, China, Japan, the United Kingdom, Germany, France, the OECD, and elsewhere, and their impact on U.S. business. Also discussed in detail are the advance pricing agreements (APA) programs of the United States and Canada; a new paradigm for resolving a variety of issues that have arisen recently in intrafirm trade and transfer pricing; and, for business executives, an approach for managing a corporate transfer pricing system. The book is an essential reading for professionals and their colleagues in the academic community.
Download or read book Multinationals Beyond the Market written by Robin Murray and published by New York : Wiley. This book was released on 1981 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Current Trends and Corporate Cases in Transfer Pricing written by Roger Y. Tang and published by Praeger. This book was released on 2002-04-30 with total page 208 pages. Available in PDF, EPUB and Kindle. Book excerpt: Global changes in business and tax environments are having profound impact on the volume and direction of intrafirm trade and transfer pricing strategies. Tang reports on the findings of a survey of 95 Fortune 1000 companies, sponsored by the Institute of Management Accountants, and provides highly relevant information not easily found on how companies are reacting to this new business environment. He covers corporate financial goals and strategies and divisonal performance measurements systems, among other topics, and gives highly detailed case studies based on reports from five major respondents to his survey: Whirlpool, Dow Chemical, Guidant Corporation, Masco, and Eaton. Tang's book is essential, up-to-date reading for upper level students, researchers, analysts, and corporate executives in multinational firms worldwide. Tang starts with a presentation of the major changes in the global business environment and explains their impact on intrafirm trade and transfer pricing. In Chapter 2 he reports results of his questionnaire survey, and in Chapters 3 to 7 examines up close the details revealed in his five corporate case studies. He compares these corporations in Chapter 8, focusing on corporate strategies and financial goals, transfer pricing and performance evaluation practices, and concommitant tax planning strategies. He then relates his case study research to other major findings derived from his questionnaire survey, and ends the book with a general, summarizing, analytical conclusion.
Download or read book On the Effects of Transfer Pricing Regulations written by Sabine Laudage Teles and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Multinational profit shifting by mis-pricing of intra-firm trade is a major concern for less developed countries (LDCs). Many have enacted transfer pricing rules in order to constrain this type of tax avoidance behavior. Yet, not much is known on the rules' fiscal and economic effects. We offer a first empirical assessment, drawing on data for more than 120 low- and middle-income countries for a 30-year-period. Our results suggest that the introduction of transfer pricing regulations significantly increased corporate tax revenue collection in LDCs. The effect is fiscally sizable but fades out over time. We do not find indication for negative investment responses to the regulations.
Download or read book Taxing Multinationals written by Lorraine Eden and published by University of Toronto Press. This book was released on 1998-01-01 with total page 788 pages. Available in PDF, EPUB and Kindle. Book excerpt: Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public 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 Intra firm Trade written by Organisation for Economic Co-operation and Development and published by . This book was released on 1993 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Fundamentals of International Transfer Pricing in Law and Economics written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2012-02-15 with total page 308 pages. Available in PDF, EPUB and Kindle. Book excerpt: The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Download or read book International Taxation and Multinational Activity written by James R. Hines and published by University of Chicago Press. This book was released on 2009-02-15 with total page 285 pages. Available in PDF, EPUB and Kindle. Book excerpt: Because the actions of multinational corporations have a clear and direct effect on the flow of capital throughout the world, how and why these firms behave the way they do is a major issue for national governments and their policymakers. With an unprecedented ability to adjust the scale, character, and location of their global operations, international corporations have become increasingly sensitive to the kind and degree of tax obligations imposed on them by both host and home countries. Tax rules affect the volume of foreign direct investment, corporate borrowing, transfer pricing, dividend and royalty payments, and research and development. National governments that tax the profits of international firms face important challenges in designing tax policies to attract them. This collection examines the global ramifications of tax policies, offering up-to-date, theoretically innovative, and empirically sound perspectives on a problem of immense significance to future economic growth around the globe.
Download or read book The Oxford Handbook of International Business written by Alan M. Rugman and published by OUP Oxford. This book was released on 2010-08-26 with total page 880 pages. Available in PDF, EPUB and Kindle. Book excerpt: As globalization explodes, so has international business scholarship. This second edition of the Oxford Handbook of International Business synthesises all the relevant literature of the last 40 years in 28 original chapters by the world's most distinguished scholars. Reflecting the changes and development in the field since the first edition this new edition has a changed structure, all the chapters have been updated to take account of the latest scholarship, and five new chapters freshly written. The Handbook is divided into six major sections, providing comprehensive coverage of the following areas: · History and Theory of the Multinational Enterprise · The Political and Regulatory Environment · Strategy and International Management · Managing the MNE · Area Studies · Methodological Issues These state of the art literature reviews will be invaluable references for students in business schools, social sciences, law, and area studies.
Download or read book International Corporate Tax Avoidance A Review of the Channels Magnitudes and Blind Spots written by Sebastian Beer and published by International Monetary Fund. This book was released on 2018-07-23 with total page 45 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
Download or read book The Transfer Pricing of Intangibles written by Michelle Markham and published by Kluwer Law International B.V.. This book was released on 2005-01-01 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
