Download or read book Taxing Multinationals written by Lorraine Eden and published by University of Toronto Press. This book was released on 1998-01-01 with total page 788 pages. Available in PDF, EPUB and Kindle. Book excerpt: Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.

Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 written by OECD and published by OECD Publishing. This book was released on 2017-07-10 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt: This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 written by OECD and published by OECD Publishing. This book was released on 2022-01-20 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.

Download or read book Transfer Pricing and Multinational Enterprises written by OECD and published by OECD Publishing. This book was released on 1979-06-01 with total page 107 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.

Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 written by OECD and published by OECD Publishing. This book was released on 2009-08-18 with total page 247 pages. Available in PDF, EPUB and Kindle. Book excerpt: OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.

Download or read book International Taxation and Multinational Activity written by James R. Hines and published by University of Chicago Press. This book was released on 2009-02-15 with total page 285 pages. Available in PDF, EPUB and Kindle. Book excerpt: Because the actions of multinational corporations have a clear and direct effect on the flow of capital throughout the world, how and why these firms behave the way they do is a major issue for national governments and their policymakers. With an unprecedented ability to adjust the scale, character, and location of their global operations, international corporations have become increasingly sensitive to the kind and degree of tax obligations imposed on them by both host and home countries. Tax rules affect the volume of foreign direct investment, corporate borrowing, transfer pricing, dividend and royalty payments, and research and development. National governments that tax the profits of international firms face important challenges in designing tax policies to attract them. This collection examines the global ramifications of tax policies, offering up-to-date, theoretically innovative, and empirically sound perspectives on a problem of immense significance to future economic growth around the globe.

Download or read book Fundamentals of International Transfer Pricing in Law and Economics written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2012-02-15 with total page 308 pages. Available in PDF, EPUB and Kindle. Book excerpt: The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.

Download or read book Transfer Pricing 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 Dealing Effectively with the Challenges of Transfer Pricing written by OECD and published by OECD Publishing. This book was released on 2012-01-18 with total page 110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report addresses the practical administration of transfer pricing programmes by tax administrations.

Download or read book The Effects of Taxation on Multinational Corporations written by Martin Feldstein and published by University of Chicago Press. This book was released on 2007-12-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.

Download or read book Multinationals and Transfer Pricing written by Alan M. Rugman and published by Routledge. This book was released on 2017-02-03 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: One of the reasons for the success of multinational enterprises in their ability to create in their supranational organisations "internal markets" which eliminate the imperfections of external world markets caused by tariffs on trade, restrictions on the flow of capital, information costs and so on. The method multinationals use to create and sustain internal markets is transfer pricing. Multinationals use to their advantage the difference between nominal accounting and real transfers from their head offices to a subsidiary in different countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals’ use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.

Download or read book Introduction to Transfer Pricing written by Jerome Monsenego and published by . This book was released on 2013-01-01 with total page 163 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.

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 286 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 International Transfer Pricing written by Business International Corporation and published by . This book was released on 1991 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: A comprehensive guide to corporate practices in internal control and tax compliance. Included are case studies of how firms in a variety of industries approach transfer pricing.

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 Transfer Pricing and Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2008-10-11 with total page 199 pages. Available in PDF, EPUB and Kindle. Book excerpt: National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.

Download or read book Transfer Pricing and the Arm s Length Principle in International Tax Law written by Jens Wittendorff and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 914 pages. Available in PDF, EPUB and Kindle. Book excerpt: The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.