Download or read book Transfer Pricing Aspects of Intra group Loans in Light of the Base Erosion and Profit Shifting Action Plan written by V. Chand and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article primarily focuses on transfer pricing aspects of intercompany loans. The analysis takes into consideration the current OECD Transfer Pricing Guidelines as well as the revised transfer pricing guidance issued under the OECD/G20's Base Erosion and Profit Shifting (BEPS) Action Plan. Moreover, the impact of other BEPS-related actions on intercompany loans and their relationship with transfer pricing rules is discussed. Finally, the author concludes by making a suggestion to the OECD to adopt his analysis when providing transfer pricing guidance on intercompany loans.
Download or read book Transfer Pricing Intra group Financing written by Antonio Russo and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This chapter is based on information available up to 7 March 2014. The main changes made to this chapter up to that date are: in July 2013 the Action Plan on Base Erosion and Profit Shifting was published; and, Actions 1 and 2 of the Action Plan on BEPS focus on hybrid instruments and entities.
Download or read book Applying the Arm s Length Principle to Intra group Financial Transactions written by Robert Danon and published by Kluwer Law International B.V.. This book was released on 2023-08-29 with total page 1053 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
Download or read book Transfer Pricing and Intra group Financing written by Anuschka Bakker and published by IBFD. This book was released on 2012 with total page 593 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
Download or read book Transfer Pricing Aspects of Intra Group Financing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2013-10-20 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.
Download or read book Transfer Pricing Aspects of Cash Pooling Arrangements in Light of the BEPS Action Plan written by Vikram Chand and published by . This book was released on 2016 with total page 10 pages. Available in PDF, EPUB and Kindle. Book excerpt: The author discusses the concept, underlying commercial rationale and types of cash pooling arrangements, and then analyses and comments on the transfer pricing aspects thereof. The analysis also takes into consideration the Actions under the OECD/G20 BEPS Project related to transfer pricing. The author discusses the impact of other BEPS-related actions (domestic and treaty law changes) on cash pooling arrangements, and ultimately suggests a way forward.
Download or read book Transfer Pricing Aspect of Intra group Financial Guarantees Post BEPS written by Heather Marwei and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book TRANSFER PRICING AND INTRA GROUP FINANCING written by Anuschka Bakker and published by . This book was released on 2021 with total page 933 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the second revised edition of the book published in 2012, and addresses the topic of intra-group financing and transfer pricing.
Download or read book Research Handbook on International Taxation written by Yariv Brauner and published by Edward Elgar Publishing. This book was released on 2020-12-25 with total page 416 pages. Available in PDF, EPUB and Kindle. Book excerpt: Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
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 G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports written by OECD and published by OECD Publishing. This book was released on 2016-08-26 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting is a key priority of governments around the globe. This Explanatory Statement offers an overview of the BEPS Project and outcomes.
Download or read book Exchange of Information in the EU written by Marina Serrat Romaní and published by Edward Elgar Publishing. This book was released on 2024-04-12 with total page 391 pages. Available in PDF, EPUB and Kindle. Book excerpt: This timely book provides a holistic analysis of the exchange of information procedures for tax purposes within the EU from an administrative law and tax law perspective. It explores how procedural and substantive taxpayers’ rights are affected by exchange of information processes, and rigorously examines the effectiveness of the current legal framework.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation Interim Report 2018 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2018-03-16 with total page 218 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.
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 Tax Avoidance in Sub Saharan Africa s Mining Sector written by Ms. Giorgia Albertin and published by International Monetary Fund. This book was released on 2021-09-28 with total page 73 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper aims to contribute to the international policy debate around profit shifting, tax avoidance and SSA’s revenue mobilization efforts in three ways. First, it examines the importance of mining, the role of multinational enterprises (MNEs), and mining revenue outcomes in SSA. Second, it assesses the magnitude of profit shifting in mining drawing on new macro level research, supplemented by case studies to illustrate the lived experience of tax avoidance in SSA mining. Third, the paper identifies tax policy reforms that could boost revenue mobilization in SSA.
Download or read book The Alternative Investment Fund Managers Directive written by Dirk A. Zetzsche and published by Kluwer Law International B.V.. This book was released on 2015-09-14 with total page 948 pages. Available in PDF, EPUB and Kindle. Book excerpt: Apart from MiFID, the Alternative Investment Fund Managers Directive (AIFMD) may be the most important European asset management regulation of the early twenty-first century. In this in-depth analytical and critical discussion of the content and system of the directive, thirty-eight contributing authors – academics, lawyers, consultants, fund supervisors, and fund industry experts – examine the AIFMD from every angle. They cover structure, regulatory history, scope, appointment and authorization of the manager, the requirements for depositaries and prime brokers, rules on delegation, reporting requirements, transitional provisions, and the objectives stipulated in the recitals and other official documents. The challenging implications and contexts they examine include the following: – connection with systemic risk and the financial crisis; - nexus with insurance for negligent conduct; - connection with corporate governance doctrine; - risk management; - transparency; - the cross-border dimension; - liability for lost assets; - impact on alternative investment strategies, and - the nexus with the European Regulation on Long-Term Investment Funds (ELTIFR). Nine country reports, representing most of Europe’s financial centres and fund markets add a national perspective to the discussion of the European regulation. These chapters deal with the potential interactions among the AIFMD and the relevant laws and regulations of Austria, France, Germany, Italy, Luxembourg, Liechtenstein, The Netherlands, Malta and the United Kingdom. The second edition of the book continues to deliver not only the much-needed discussion of the inconsistencies and difficulties when applying the directive, but also provides guidance and potential solutions to the problems it raises. The second edition considers all new developments in the field of alternative investment funds, their managers, depositaries, and prime brokers, including, but not limited to, statements by the European Securities and Markets Authority (ESMA) and national competent authorities on the interpretation of the AIFMD, as well as new European regulation, in particular the PRIIPS Regulation, the ELTIF Regulation, the Regulation on European Venture Capital Funds (EuVeCaR), the Regulation on European Social Entrepreneurship Funds (EUSEFR), MiFID II, and UCITS V. The book will be warmly welcomed by investors and their counsel, fund managers, depositaries, asset managers, administrators, as well as regulators and academics in the field.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements Action 2 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2017-07-27 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).
