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 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 Restricting the Interplay of Transfer Pricing and Customs Valuation CJEU Ruling on Related Party Imports Subject to Retroactive Adjustments written by R. Petruzzi and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The issue of retroactive transfer pricing (TP) adjustments altering customs valuation has been a long-standing question involving many multinational enterprises (MNEs). While customs authorities have traditionally ruled that upward adjustments to transfer prices should be accompanied by revisions to customs value under the transaction value method, MNEs have sought refunds in the event of downward adjustments. Realising the need for guidance, the World Customs Organisation (WCO) continues its efforts to align transfer pricing and customs valuation outcomes. However, in a recent landmark ruling (C-529/16, Hamamatsu Photonics Deutschland), the Court of Justice of the European Union (CJEU) has affirmed that transfer prices subjected to retroactive adjustments cannot be used for customs valuation purposes under the application of the transaction value method. The ruling leaves room for diverging interpretations and consequent uncertainties.
Download or read book Virtues and Fallacies of VAT An Evaluation after 50 Years written by Robert F. van Brederode and published by Kluwer Law International B.V.. This book was released on 2021-08-09 with total page 615 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value-added tax (VAT) is a mainstay of revenue systems in more than 160 countries. Because consumption is a more stable revenue base than other tax bases, VAT is less distorting and hence more likely to encourage investment, savings, optimum labor supply decisions, and growth. VAT is not without criticism however, and faces its own specific technical and policy challenges. This book, the first to thoroughly evaluate VAT from a global policy perspective after over 50 years of experience with its intricacies, offers authoritative perspectives on VAT’s full spectrum—from its signal successes to the subtle ways its application can undermine revenue performance and economic neutrality. The contributors—leading tax practitioners and academics—examine the key policy issues and topics that are crucially relevant for measuring the success of the tax in the first part of the book, including: revenue generation and revenue efficiency; single rate versus multiple rates; susceptibility to fraud; exemptions and exceptions; compliance cost for businesses; policy and compliance gaps in revenue collection; adjustment rules caused by the transactional nature of the tax; transfer pricing issues; treatment of vouchers; permanent establishments and holding companies; payment of refunds; cross-border digital transactions; and supplies for free or below cost price. The second part offers six country reports—on New Zealand, Japan, China, Colombia, Ethiopia, and India—to demonstrate the different ways in which VAT operates in a variety of national economies. Whether a government is contemplating the imposition of a general consumption tax for the first time or new rules for applying an existing one, it is important for policymakers to keep central the aim to design a tax that realizes optimal efficiency and causes minimal distortions. This invaluable book serves as an expert guide to VAT policy development in this area. It will be welcomed not only by concerned government officials but also by tax professionals (both lawyers and accountants) and academics in tax law.
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 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 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 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 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 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 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 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 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 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 Charles Pettigrew First Bishop elect of the North Carolina Episcopal Church written by Bennett H Wall and published by Hassell Street Press. This book was released on 2021-09-10 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: This work has been selected by scholars as being culturally important and is part of the knowledge base of civilization as we know it. This work is in the public domain in the United States of America, and possibly other nations. Within the United States, you may freely copy and distribute this work, as no entity (individual or corporate) has a copyright on the body of the work. Scholars believe, and we concur, that this work is important enough to be preserved, reproduced, and made generally available to the public. To ensure a quality reading experience, this work has been proofread and republished using a format that seamlessly blends the original graphical elements with text in an easy-to-read typeface. We appreciate your support of the preservation process, and thank you for being an important part of keeping this knowledge alive and relevant.
Download or read book Truth Is a Woman written by Loren Jakobov and published by Createspace Independent Publishing Platform. This book was released on 2017-09-12 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt: Truth Is A Woman is a poetry collection by Loren Jakobov written in response to her friends tragic death in 2015 as a victim of rape and murder. The poems discuss the World from the eyes of a woman, the pain and the beauty that lies therein.
Download or read book Elmer Again written by David McKee and published by . This book was released on 1991 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: Elmer, the patchwork elephant, plays an amusing trick on his grey elephant friends.
