Download or read book Transfer Pricing and Customs Valuation how Can We finally Bridge the Gap written by G. Piran and published by . This book was released on 2018 with total page 62 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing and customs are separate legal disciplines and rely on different legal instruments. Transfer pricing and customs, in fact, aim at solving different issues and, therefore, the authorities appointed to supervise their application might have diverging interests. This thesis examines the interaction of the valuation processes carried on under the two legal disciplines. It provides an analysis of relevant regulations and literature and case law and is completed by the consideration of administrative practices in Italy, South Korea, UK and the USA, with the purpose of identifying the instruments currently available to economic operators to deal with the problem presented. The purpose of the paper was to identify the status quo of the subject and, whenever the issue of the imperfect interaction between transfer pricing and customs valuation methods was persisting, to propose a comprehensive solution to it.

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 Customs Valuation and Transfer Pricing Is It Possible to Harmonize Customs and Tax Rules written by Juan Jovanovich and published by Springer. This book was released on 2002-10-30 with total page 168 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although valuation is fundamental to both tax and customs liability in international transactions, values calculated by the two regimes can differ, often markedly, in situations where no clear rules of transfer pricing apply. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, Customs Valuation and Transfer Pricing offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized.Among the essential elements of this important thesis, the author discusses the following in depth: the OECD Transfer Pricing Guidelines; the GATT/WTO Valuation Code (GVC); the arm's length principle; methods, both traditional and new, of determining whether the parties' relationship influenced the price; and additions to and deductions from the customs value. The study concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing compensatory adjustments to transaction value would be consistent with Article 1 of the GVC.

Download or read book Customs Valuation and Transfer Pricing Legal Rules Practices a China Case Study and Proposals to Address the Significant Concern for Cost efficient Compliance and Trade Facilitation written by Zhaokang Jiang and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The intertwined relationship between customs valuation and transfer pricing has caused significant concern of costs for international trade compliance and efficiency. There are sets of international and national rules for the two related matters of similar purpose, and the gap between the rules and administrations is obvious and room to improve significant. The China case study calls the public and private sectors to work together for a better business climate for compliance and efficiency in this regard. In this respect the author considers the following issues to be improved in public sector: (1) awareness and willingness of rule-based fair and efficient administration; (2) capacity building; (3) international model legislation; (4) transparency and consistency with detailed implementing rules and reasoning-based ruling program; (5) data sharing and risk management; (6) inter-agency cooperation; (7) functional reorganization; (8) standards, methods, documentation compliance requirements and liabilities for encouraging compliance; (9) analysis from the legal and reasoning perspectives; (10) reconciliation and refund mechanism.

Download or read book Linking Customs Valuation and Transfer Pricing in the U S And Beyond written by Joshua Simmons and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The exponential growth of international trade and the rapid expansion of corporate supply chains due to the rapid globalization of recent decades have placed increasing strains on systems of trade regulation and tax administration designed for a world of discrete states and corporate entities. A particular area where this tension has become pronounced is in the disconnect between customs valuation and transfer pricing, the legal regimes for valuing international transactions for purposes of assessing import tariffs and corporate income tax respectively. While both systems establish similar broad baselines -- the “arm's-length principle” for transfer pricing and the “transaction value principle” for customs valuation -- because of the different goals of each system and the scope of transactions to which each applies, the specific methods used differ, leading to confusion and inefficiency. Efforts to coordinate the two systems, both at an international level and in the U.S., are progressing but incomplete. This paper illuminates the disparity in these two systems, with a specific focus on the U.S, through studying current laws, regulations, and practices in both areas, along with the steps taken thus far to align them, concluding with recommendations for how these efforts should be continued. This paper was written for the Transfer Pricing: Special Topics graduate-level seminar at Georgetown University Law Center during the Spring 2015 term.

Download or read book Customs Valuation and Transfer Pricing ICC Proposals written by J-M. Salva and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The article studies the relationship between transfer pricing and customs valuation. The author explains two different approaches of transfer pricing, the first one adopted by tax agencies, based on the OECD Transfer Pricing Guidelines and the second adopted by customs agencies, based on the WTO Customs Valuation Agreement (CVA). From the business perspective, the divergence between the two taxation regimes is an obstacle to the liberalization of trade and inhibits international development for companies. On the other hand, the International Chamber of Commerce (ICC) believes that the WTO CVA and the use of the OECD Guidelines are enough to settle the issue of customs valuation and transfer pricing. However, ICC specifies that tax and customs approaches of intercompany transactions should converge to the same value. In this goal, ICC published a policy statement in 2012, which has been integrated in the WCO guidelines. This statement, based on the harmonization of the current rules, contains several additional options to derive customs value. The author states that the Union Customs Code does not contain any evolution from a transfer pricing perspective but contains some negatives changes regarding custom valuation. Also, the opportunity of the WCO Free Trade Agreement should be taken to move forward on this issue.

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 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 Unified Financial Analysis written by Willi Brammertz and published by John Wiley & Sons. This book was released on 2011-11-04 with total page 463 pages. Available in PDF, EPUB and Kindle. Book excerpt: Unified Financial Analysis arrives at the right time, in the midst of the current financial crisis where the call for better and more efficient financial control cannot be overstated. The book argues that from a technical perspective, there is no need for more, but for better and more efficiently organized information. The title demonstrates that it is possible with a single but well organized set of information and algorithms to derive all types of financial analysis. This reaches far beyond classical risk and return or profitability management, spanning all risk categories, all valuation techniques (local GAAP, IFRS, full mark-to-market and so on) and static, historic and dynamic analysis, just to name the most important dimensions. The dedication of a complete section to dynamic analysis, which is based on a going concern view, is unique, contrasting with the static, liquidation-based view prevalent today in banks. The commonly applied arbitrage-free paradigm, which is too narrow, is expanded to real world market models. The title starts with a brief history of the evolution of financial analysis to create the current industry structure, with the organisation of many banks following a strict silo structure, and finishes with suggestions for the way forward from the current financial turmoil. Throughout the book, the authors advocate the adoption of a 'unified financial language' that could also be the basis for a new regulatory approach. They argue that such a language is indispensable, if the next regulatory wave – which is surely to come – should not end in an expensive regulatory chaos. Unified Financial Analysis will be of value to CEOs and CFOs in banking and insurance, risk and asset and liability managers, regulators and compliance officers, students of Finance or Economics, or anyone with a stake in the finance industry.

Download or read book Pricing the Priceless written by Paula DiPerna and published by John Wiley & Sons. This book was released on 2023-06-14 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt: An exciting exploration of the new frontier of finance, to value the planet and protect what has too long been treated as free and taken for granted--the natural assets we need and love most In Pricing the Priceless: The Financial Transformation to Value the Planet, Solve the Climate Crisis, and Protect Our Most Precious Assets, renowned environmental strategist, speaker, world traveler and author Paula DiPerna brings a unique voice and optic to de-mystify and unveil today’s most fascinating financial disruption—pricing the priceless to flip conventional ideas of how we value natural assets and why. She asks the provocative question long ignored: Why do we value the indispensable atmosphere at zero, but dispensable production in the trillions? She digs into alternatives, with real-life examples from around the globe of fascinating and pioneering financial innovations—controversial and paradoxical, but essential. In the book, you’ll travel from rainforests to Wall Street, Board Rooms to the Vatican, coral reefs to mangroves to China’s carbon markets. Timely, adventurous, eclectic, and accessible, Pricing the Priceless brings alive the critical financial transformation that will determine future planetary health and social stability. With power, clarity and real-world experience, the author also examines: Fascinating new financial inventions and experiments—insurance, bonds, markets, investment funds—all aimed at pricing what is precious and vital to human well-being How the great current intergenerational shift in wealth and attitudes is redefining investment trends and the idea of what constitutes wealth and return How climate change and other urgent environmental problems now require entirely new financial thinking to trigger solutions How once-radical ideas about measuring economic progress are now re-imagining the very purpose of capitalism Why finance needs critical re-invention to remain credible in the face of increasing public skepticism of business-as-usual economic practice A can’t-miss read for thought leaders, business executives, investors, activists, and entrepreneurs, Pricing the Priceless is a landmark that will shape the world and future, bridging the tangible and intangible to answer a critical question of rising economic and social inspiration: What is money for?

Download or read book Just Security in an Undergoverned World written by William J. Durch and published by Oxford University Press. This book was released on 2018 with total page 541 pages. Available in PDF, EPUB and Kindle. Book excerpt: Just Security in an Undergoverned World examines how humankind can manage global problems to achieve both security and justice in an age of antithesis. Global connectivity is increasing, visibly and invisibly-in trade, finance, culture, and information-helping to spur economic growth, technological advance, and greater understanding and freedom, but global disconnects are growing as well. Ubiquitous electronics rely on high-value minerals scraped from the earth by miners kept poor by corruption and war. People abandon burning states for the often indifferent welcome of wealthier lands whose people, in turn, draw into themselves. Humanity's very success, underwritten in large part by lighting up gigatons of long-buried carbon for 200 years, now threatens humanity's future. The global governance institutions established after World War Two to manage global threats, especially the twin scourges of war and poverty, have expanded in reach and impact, while paradoxically losing the political support of their wealthiest and most powerful members. Their problems mimic those of their members in struggling to adapt to new problems and maintain trust in institutions. This volume argues, however, that a properly mandated, managed, and modernized global architecture offers unparalleled potential to midwife solutions to vexing issues that transcend borders and capacities of individual actors, from conflict and climate change to poverty and pandemic disease. The volume offers 'just security' as a new framework for evaluating innovative solutions and strategies for institutional reform.

Download or read book United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 written by United Nations and published by . This book was released on 2017 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.

Download or read book Transfer Pricing Developments Around the World 2019 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2019-08-09 with total page 290 pages. Available in PDF, EPUB and Kindle. Book excerpt: Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based papers prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics: Global Transfer Pricing Developments; Transfer Pricing Developments in the European Union; Transfer Pricing Developments in the United States; Transfer Pricing Developments in Developing Countries and Emerging Economies; Recent Developments on Transfer Pricing and Intra-Group Services; Recent Developments on Transfer Pricing and Intra-Group Financing; Recent Developments on the Nexus Rules to Tax Business Profits at Source; and Recent Developments on Attribution of Profits to Digital Permanent Establishments. The intense work of international organizations such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations as well as the intense work of the European Union is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.

Download or read book Importing Into the United States written by U. S. Customs and Border Protection and published by . This book was released on 2015-10-12 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains process of importing goods into the U.S., including informed compliance, invoices, duty assessments, classification and value, marking requirements, etc.

Download or read book International Convergence of Capital Measurement and Capital Standards written by and published by Lulu.com. This book was released on 2004 with total page 294 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book World Development Report 2020 written by World Bank and published by World Bank Publications. This book was released on 2019-11-19 with total page 511 pages. Available in PDF, EPUB and Kindle. Book excerpt: Global value chains (GVCs) powered the surge of international trade after 1990 and now account for almost half of all trade. This shift enabled an unprecedented economic convergence: poor countries grew rapidly and began to catch up with richer countries. Since the 2008 global financial crisis, however, the growth of trade has been sluggish and the expansion of GVCs has stalled. Meanwhile, serious threats have emerged to the model of trade-led growth. New technologies could draw production closer to the consumer and reduce the demand for labor. And trade conflicts among large countries could lead to a retrenchment or a segmentation of GVCs. World Development Report 2020: Trading for Development in the Age of Global Value Chains examines whether there is still a path to development through GVCs and trade. It concludes that technological change is, at this stage, more a boon than a curse. GVCs can continue to boost growth, create better jobs, and reduce poverty provided that developing countries implement deeper reforms to promote GVC participation; industrial countries pursue open, predictable policies; and all countries revive multilateral cooperation.