Download or read book Transfer Pricing in a Post BEPS World written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2016-04-20 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD’s Base Erosion and Profit Shifting (BEPS) project promises to make effective inroads into the much criticized corporate tax strategy known as aggressive transfer pricing, whereby the profitability of subsidiaries in different jurisdictions is “managed” via mispricing with the intent of minimizing the corporation’s overall tax burden. Although the OECD BEPS project is an ongoing endeavor, its accomplishments to date and developing trends are discernible. This book, including contributions by outstanding and renowned transfer pricing experts both from practice and academia, analyses these trends, and proposes reforms which would ensure that transfer pricing outcomes are better aligned with economic activities and value creation, which achieves a more equitable distribution of profits among different countries. Each chapter is dedicated to specific sections of the OECD’s BEPS Action Plan. Among the topics and issues covered are the following: – arm’s length principle and its ongoing development; – allocation of risk and recharacterization; – intangibles (both license model and cost contribution arrangements); – interest deductions and intra-group financing; – low value-adding services; – commissionaire arrangements and low-risk distributors; – attribution of profits to permanent establishments; – documentation requirements (including Country-by-Country Reporting). Within these topics, measures to identify the commercial and financial relationships inside multinational enterprises, to accurately delineate actual transactions, as well as guidance on defining risk and its allocation among entities of a multinational enterprise are discussed. The book is based on papers presented and discussed at the first Global Transfer Pricing Conference hosted in February 2016 by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business). The most up-to-date and thorough consideration of transfer pricing yet published, this book will prove invaluable for all parties currently facing questions related to transfer pricing in a post-BEPS world, especially those in charge of finding an ideal answer to them: academics, practitioners (including in-house and advisory counsel), international organizations, CEOs and CFOs of multinational enterprises, and government officials who are tax and transfer pricing experts.

Download or read book Transfer Pricing Risks Post BEPS A Practical Guide written by Fabrizio Lolliri and published by Tolley. This book was released on 2017-12-12 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing has never had as much media exposure as last year and keeps showing up on the headlines of all major newspapers and other media. Political pressure and the increasing government deficit that is affecting most of the countries are putting a lot of pressure on tax authorities worldwide to fill in the budget gap and are driving a more aggressive and inquisitive approach towards tax payers. The OECD embarked on a very difficult mission with its Base Erosion and Profit Shifting ("BEPS") project, which started with the G20 in 2012. The world of Transfer Pricing as we know it is changing as the BEPS project continues to raise new issues with the existing structures setup by large multinational and often driven by the desire to achieve better tax efficiency. Although, the BEPS project is well advanced, only few countries have already issued new legislation and amendments to transfer pricing regulations to comply with the new principles from the BEPS project. The lack of clarity on how BEPS will translate in all the different jurisdictions is a concern for not just tax directors, but also CEOs and CFOs. Transfer Pricing Risks Post-BEPS: A Practical Guide explores the issues raised by the BEPS project and offers the readers a practical approach to risk assessment and mitigation in preparation for new legislation and rules to come. The readers are also guided through how supply chain planning is likely to change in the future and how businesses can still ensure their vision and strategy can be implemented whilst minimising risk and improving efficiencies that go hand in hand with real commercial planning.

Download or read book Substance in Transfer Pricing in a Post BEPS World and Beyond written by R. Petruzzi and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the authors examine the notion of substance for transfer pricing purposes in the pre- and post-BEPS era and provide some considerations in light of the current discussions on the digitization, digitalization and digital transformation of the economy.

Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.

Download or read book Transfer Pricing Aspects of Transactions with Marketing Intangibles in a Post BEPS World written by A. Fedi and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article analyses the different types of marketing intangibles and their features and examines the intra-company transactions and contractual arrangements in which they can be involved. The article further describes the difficulties in identifying marketing intangibles, attributing their ownership and correctly pricing them. The author analyses past and present guidance and describes some real cases judged both in a pre-BEPS world and in a post-BEPS world in order to show the evolution of various tax authorities' decisions in relation to marketing intangibles transactions.

Download or read book Transfer Pricing Developments Around the World 2020 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2020-09-28 with total page 312 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 chapters 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 the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules); Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules); Recent Developments on Transfer Pricing and Intra-Group Financing; and Recent Developments on the Use of New Technologies for Transfer Pricing Analyses. 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 OECD Transfer Pricing Guidelines as a Quasi Source of Law in a Post BEPS World Legislative and Judicial Developments from a Polish Perspective written by B. Brzeziński and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations are of the utmost importance in the sphere of transfer pricing. Unlike article 9 of the OECD Model, which is rather general in wording, the OECD Transfer Pricing Guidelines offer a detailed guidance on transfer pricing methodology. The significance of the OECD Transfer Pricing Guidelines became even more noticeable when the BEPS Project was completed, because numerous changes to the global transfer pricing regime were envisaged in the amended guidelines and not in the text of the OECD Model itself. The aim of this article is to analyse the status of the OECD Transfer Pricing Guidelines in international and Polish domestic law, as well as current practice of their application.

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 Taxing Global Digital Commerce in a Post BEPS World written by Arthur J. Cockfield and published by . This book was released on 2018 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This chapter evaluates the recent OECD Base Erosion and Profit Shifting (BEPS) initiative directed at global digital income, and concludes that tax planning will not be inhibited by any significant extent. Tax planners and academics nevertheless should take into account prospective reforms surrounding permanent establishments, hybrid entities, treaty shopping, transfer pricing and controlled foreign corporations, which may challenge certain practices.

Download or read book Transfer Pricing Developments Around the World 2022 written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2022-10-11 with total page 292 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 a 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 chapters 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 in the Post-Covid-19 Era. Recent Developments on Transfer Pricing and Substance. Recent Developments on Transfer Pricing and Business Restructurings. Recent Developments on Transfer Pricing and New Technologies. The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, 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 interested academics in facilitating efficient dialog and a coordinated approach to transfer pricing in the future.

Download or read book Taxmann s BEPS Implications on Transfer Pricing Indian Perspective Comprehensive and Practical Guide with Analysis Case Studies Practical Strategies for Tax Professionals written by Ashutosh Mohan Rastogi and published by Taxmann Publications Private Limited. This book was released on 2024-07-09 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book offers a comprehensive and practical guide to understanding the intricate transfer pricing implications stemming from the Base Erosion and Profit Shifting (BEPS) project within the Indian context. This work culminates two years of extensive research and analysis by a team of transfer pricing experts. The book covers a wide range of topics, starting with an overview of the BEPS project and its objectives. It also includes an analysis of international rulings on BEPS, examining landmark cases and their implications for the transfer pricing landscape. This comprehensive guide is invaluable for tax practitioners, professionals, academics, and business leaders aiming to understand the impact of BEPS recommendations on transfer pricing in India. It facilitates informed discussions on this critical area of taxation and its implications for businesses operating in India. The Present Publication is the Latest Edition, authored by Ashutosh Mohan Rastogi, with the following noteworthy features: • [Realignment of Transfer Pricing Norms] The book explains why BEPS realigned 'Transfer Pricing' norms, illustrated through case studies of Google, Starbucks, and Apple, highlighting their implications on BEPS • [Understanding and Application of BEPS Action Plans] BEPS Action plans have transformed how Transfer Pricing concepts are understood and applied, shifting focus from titles and contracts to functions and risks. This book helps readers understand these nuances in the post-BEPS era • [BEPS Insights on Indian Law] Each chapter provides BEPS insights on Indian Law, discussing BEPS Action plans with reference to Indian Regulations, Circulars, and Case Law and explaining the relevance and implications of BEPS Action points in the Indian context • [Planning for Intangibles in the Post-BEPS World] The book decodes how to attribute profits to intangibles in the BEPS era, explains 'Development, Enhancement, Maintenance, Protection and Exploitation' (DEMPE) functions, and assesses the relevance of holding companies in low-tax havens today • [Economic Ownership] Readers will learn about the importance of Economic Ownership and how it is determined, exploring how Indian law attributes intangible returns based on legal or economic ownership • [Substance in Transfer Pricing] The book discusses the role of substance in Transfer Pricing, exploring whether Transfer Pricing officers can look beyond agreements to uncover reality and the role of significant people functions • [Benchmarking for Financial Transactions] It provides insights on benchmarking for financial transactions such as inter-company loans and guarantees, highlighting the importance of credit rating in financial transaction analysis and how to compute a credit rating • [Location Savings] The book explains where location savings should be taxed and whether profit split is the correct methodology for taxing location savings • [Defending Management Charges] It guides Multinational Enterprises (MNEs) on defending management charges, the availability of Safe Harbour for Management Charges in India, and the shortcomings of the safe harbour • [Cost Contribution Agreements] Readers will understand what cost contribution agreements are and how they differ from intra-group service agreements • [International Rulings on BEPS] The book summarizes leading international rulings on BEPS with illustrations, helping readers understand their implications and how tax litigators can apply them in the Indian context • [Three-Tier Documentation with FAQs] From the evolution and objectives behind the three-tier approach to the requirements suggested by the OECD and their adoption into Indian legislation, the book covers it all. It includes various prescribed templates and answers to general and transaction/issue-specific FAQs addressed by the OECD in the BEPS Action Plan 13 report The detailed contents of the book are as follows: • [Introduction] o This chapter provides an overview of the BEPS project and its objectives, including case studies of companies like Starbucks, Google, and Apple, illustrating the necessity for the BEPS initiative • [BEPS Implications on Transfer Pricing] o This chapter provides an in-depth examination of BEPS implications on transfer pricing, focusing on fundamental changes proposed by the OECD and their potential impact on MNEs in India. It analyses concepts such as economic substance, substance over form, and profit shifting to low-tax jurisdictions • [DEMPE Analysis] o This chapter provides a detailed discussion of the DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) functions, highlighting the complexities of attributing profits to intangible assets and the Indian tax authorities approach to these challenges • [BEPS Guidance on 'Substance over Form'] o This chapter discusses the principle of prioritizing economic substance over contractual form, emphasizing the importance of actual business activities and behaviours in determining transfer pricing as per BEPS guidelines • [Low-Value Intra-Group Services] o This chapter examines BEPS guidelines for low value-adding intra-group services, providing simplified approaches for determining arm's length charges and outlining documentation requirements for these services • [Financial Transactions] o This chapter analyses the intricacies of transfer pricing for financial transactions. This chapter covers treasury functions, credit risk assessment, inter-company loans, and guarantees, with an emphasis on compliance with the arm's length principle • [Cost Contribution Arrangements] o This chapter explores the concept of cost contribution arrangements (CCAs) under BEPS, discussing how MNEs share the costs and benefits of joint development activities and the implications for transfer pricing • [Location Savings] o This chapter provides an analysis of location savings and location-specific advantages, offering guidance on how these factors should be incorporated into transfer pricing strategies, particularly in the Indian context • [Three-Tier Documentation] o This chapter provides a review of the BEPS-recommended three-tier documentation approach, including the master file, local file, and country-by-country report, and a discussion on how these documentation requirements are implemented in India • [Dispute Resolution Mechanism] o This chapter discusses the mechanisms for resolving transfer pricing disputes, including the mutual agreement procedure (MAP) and India's Advance Pricing Agreement (APA) program. It provides practical insights into navigating disputes under the new BEPS regime • [International Transfer Pricing Rulings on BEPS] o This chapter summarises significant international transfer pricing rulings related to BEPS, offering key takeaways and their implications for the Indian transfer pricing landscape • [Conclusion] o This chapter concludes by synthesizing the key insights and practical guidance provided in each chapter, reinforcing the importance of understanding and applying BEPS principles to transfer pricing in India

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 Transfer Pricing in One Lesson written by Oliver Treidler and published by . This book was released on 2020 with total page 138 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm's length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book's content is applicable to a global context.

Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

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 2019-01-03 with total page 500 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint 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), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.

Download or read book Transfer Pricing Developments Around the World 2018 written by Michael Lang and published by . This book was released on 2018-08-28 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: About this book: Transfer Pricing Developments Around the World 2018 presents the most recent developments around the world in the area of transfer pricing. 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 Vienna University of Economics and Business, this book offers seven topic-based chapters prepared by international experts on transfer pricing. What's in this book: Greatly helping to define where the line should be drawn to distinguish genuine transfer pricing issues from other anti-avoidance measures, 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 documentation and country-by-country reporting; recent developments on comparability analysis in transfer pricing; and recent developments on the profit split method. The intense work of international organizations such as the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund, and other international organizations is discussed in this book. How this will help you: This book provides updated information for all parties currently facing questions related to transfer pricing in a post-BEPS world and those in charge of finding an ideal answer to them. 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 interested academics in facilitating an efficient dialogue and coordinated approach to transfer pricing in the future.

Download or read book Aligning China R D Arrangements and Transfer Pricing in a Post BEPS World written by J.Y.M. Zhao and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper presents an overview of China's R&D tax incentives, transfer pricing regime, and recent R&D developments. The paper then presents options available to multinational enterprises to structure their local R&D activities and IP ownership.