Download or read book Multinationals and Transfer Pricing written by Alan M. Rugman and published by Routledge. This book was released on 2017-02-03 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: One of the reasons for the success of multinational enterprises in their ability to create in their supranational organisations "internal markets" which eliminate the imperfections of external world markets caused by tariffs on trade, restrictions on the flow of capital, information costs and so on. The method multinationals use to create and sustain internal markets is transfer pricing. Multinationals use to their advantage the difference between nominal accounting and real transfers from their head offices to a subsidiary in different countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals’ use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.
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 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 written by OECD and published by OECD Publishing. This book was released on 2017-07-10 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 written by OECD and published by OECD Publishing. This book was released on 2022-01-20 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.
Download or read book Transfer Pricing and Multinational Enterprises written by OECD and published by OECD Publishing. This book was released on 1979-06-01 with total page 107 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.
Download or read book Transfer Pricing and Multinational Enterprises Three Taxation Issues written by OECD and published by OECD Publishing. This book was released on 1984-10-01 with total page 90 pages. Available in PDF, EPUB and Kindle. Book excerpt: Digitised document - Electronic release on 24/11/2011
Download or read book Critical Concerns in Transfer Pricing and Practice written by Wagdy M. Abdallah and published by Bloomsbury Publishing USA. This book was released on 2004-07-30 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: For multinational corporations (MNCs), there is arguably no more important operational function that affects all areas of manufacturing, marketing, management, and finance as international transfer pricing—the practicing of supplying products or services across borders from one part of the organization to another. Its complexity is compounded by the impact of e-commerce, speeding the flow of goods and services; intangible assets, such as intellectual property, whose value is difficult to quantify; and the activites of policymakers around the world to update their tax laws and regulations, in efforts to close loopholes that have historically encouraged tax avoidance. In Critical Concerns in Transfer Pricing Policy and Practice, Wagdy Abdallah provides an in-depth overview of these recent trends and developments, and considers their implications for the management of MNCs. In particular, he discusses methods for pricing transferred goods and services in the e-commerce era and analyzes the most recent regulation reforms in such countries as Germany, Mexico, Japan, Canada, the United Kingdom, the United States, and the Netherlands. Anticipating increased scrutiny of MNC transfer pricing practices from governments and other external stakeholders, Abdallah outlines a set of practical recommendations for creating a successful transfer pricing system that maximizes value for the company while remaining sensitive to local policies in all of the countries in which it operates.
Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations written by OECD and published by OECD Publishing. This book was released on 2017-07-31 with total page 192 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Multinationals and Transfer Pricing written by Alan M. Rugman and published by . This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: One of the reasons for the success of multinational enterprises in their ability to create in their supranational organisations "internal markets" which eliminate the imperfections of external world markets caused by tariffs on trade, restrictions on the flow of capital, information costs and so on. The method multinationals use to create and sustain internal markets is transfer pricing. Multinationals use to their advantage the difference between nominal accounting and real transfers from their head offices to a subsidiary in different countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals' use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 written by OECD and published by OECD Publishing. This book was released on 2009-08-18 with total page 247 pages. Available in PDF, EPUB and Kindle. Book excerpt: OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.
Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010 written by OECD and published by OECD Publishing. This book was released on 2010-08-16 with total page 375 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
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 Transfer Pricing for Multinational Enterprises An Integrated Approach written by Erik Wintzer and published by GRIN Verlag. This book was released on 2007-08 with total page 61 pages. Available in PDF, EPUB and Kindle. Book excerpt: Diploma Thesis from the year 2003 in the subject Business economics - Accounting and Taxes, grade: 2,0 (B), Schmalkalden University of Applied Sciences (Economics), course: Cost Pricing und Controlling, 121 entries in the bibliography, language: English, abstract: Globalization of business has replaced the concept of national exchanges with global transactions. Consequently, the changes due to globalization play a big role in the strategy of multinational enterprises. The volume of intrafirm trade is huge and expanding rapidly as multinationals globalize their investment and trade. Today, a considerable proportion of world trade takes place within multinational enterprises. This indicates the importance of transfer pricing conspicuously. The intention of this book is to describe the challenge of transfer pricing holistically and to exhibit some options for multinational enterprises determining their transfer prices. While management accounting as well as strategic aspects of transfer prices are also relevant for enterprises, which are not multinational, external aspects (specifically tax accounting) are typically only crucial for multinationals. This book is an attempt to integrate all aspects of transfer pricing targeting practitioners as well as economists.
Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2001 Travel version written by OECD and published by OECD Publishing. This book was released on 2001-06-26 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 2001 edition of Transfer Pricing Guidelines was substantially revised in July 2010. See the current edition. This compact version of Transfer Pricing Guidelines provides the complete and current text of the OECD pricing guidelines accepted by ...
Download or read book Transfer Pricing and Multinational Corporations written by Sylvain R. F. Plasschaert and published by Gower Publishing Company, Limited. This book was released on 1979 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt: Monograph examining the practice of transfer pricing by multinational enterprises - discusses inducements for transfer pricing, such as corporation tax differentials, customs duties, and repatriation of profit (repatriation of capital), and suggests limitation of these practices by means of fiscal policy and international cooperation. Diagrams and references.
Download or read book The Great Multinational Tax Rort written by Martin Feil and published by Scribe Publications. This book was released on 2016-08-29 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: Enough is enough In 2011, Amazon paid an effective tax rate of 0.5 per cent on its UK earnings of £3.35 billion. In 2013–14, Apple Australia paid around $80 million in income tax on revenue of over $6 billion. Multinational corporations have avoided trillions of dollars of tax over the past 25 years. Tax avoidance is legal, but its massive abuse by multinationals has had a devastating effect on governments around the world, and has placed an unbearable burden on individual taxpayers and on honest local competitors. Multinational corporations generate profits in around 180 countries around the world. They work hard to avoid, reduce, or delay their tax obligations for as long as possible, and they generally succeed. Sometimes they pay nothing or, at best, the percentage of their multibillion-dollar incomes that they pay in tax is a lot less than the percentage an individual worker pays. Four accounting firms — PricewaterhouseCoopers, Ernst & Young, KPMG, and Deloitte — are the global accountants and tax advisers for the multinationals. They have been paid over $500 billion in the past 25 years to prepare annual accounts and to manage the multinationals’ tax affairs. The favourite tool of the ‘Big Four’ accountancies to minimise tax for their multinational clients is transfer pricing: a complex and confusing array of methodologies and strategies that works to reduce tax or even avoid tax payments altogether. The Great Multinational Tax Rort explains how transfer pricing developed, and describes the strategies and tactics that the Big Four global accounting firms use on behalf of their voracious clients. Written by Martin Feil, one of the few independent experts on transfer pricing and profit repatriation by multinationals — a former poacher turned gamekeeper — this is a call to arms for citizens and governments to restore a fair taxation system.
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:
