Download or read book Value Creation Analysis for Transfer Pricing Purposes written by Brigitte Baumgartner and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The author presents a practical and pragmatic option to perform value creation analysis for transfer pricing purposes. Following Michael Porter's concepts, this article addresses five steps that can help the reader understand and follow an economic analysis to align a transfer pricing policy with a company strategy.
Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi and published by Linde Verlag GmbH. This book was released on 2019-09-02 with total page 472 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Download or read book Analysing Value Creation and the Value Chain of Data Businesses written by nupur jalan and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The notion of value creation is gaining traction. Even the OECD emphasized aligning profit taxation with economic activity and value creation in the BEPS Actions 8-10 Final Reports. Further, the modern innovative business models in this era of the digital/data economy are giving rise to highly integrated value chains. The question arises as to (i) how to accurately describe these value chains in a manner that makes the value creation and value-capturing of data and digital business transparent for tax purposes; and (ii) how to analyse modern businesses acting in their very own and unique data ecosystems. Therefore, this article discusses the value creation and value chain aspects of data-driven businesses. Considering the above, this article first discusses the background of value chain analysis and its commonly used methods for transfer pricing purposes. Second, it attempts to establish a link between the concept of value creation in the data economy and the evolving data-driven business models and examines possible value chain analyses that might be able to describe these models properly. As an interim conclusion, the authors express the need for an adjustment of the current value chain analysis for digital/data-driven businesses, as it fails to integrate the ways in which the digital data ecosystem works. Therefore, for business models that rely heavily on data and for transactions that are data-intense/data-driven, the authors propose a quantitative approach, whereby the residual profit is attributed not only to profit and investment centres, but also to data function. As it is crucial for such a value chain analysis to appropriately reflect value creation, the authors also propose a framework of digital documentation tools to understand the economic reasoning behind those businesses.Full-text Paper.
Download or read book Analysing Value Creation and the Value Chain of Data Businesses written by N. Jalan and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The notion of value creation is gaining traction. Even the OECD emphasized aligning profit taxation with economic activity and value creation in the BEPS Actions 8-10 Final Reports. Further, the modern innovative business models in this era of the digital/data economy are giving rise to highly integrated value chains. The question arises as to (i) how to accurately describe these value chains in a manner that makes the value creation and value-capturing of data and digital business transparent for tax purposes; and (ii) how to analyse modern businesses acting in their very own and unique data ecosystems. Therefore, this article discusses the value creation and value chain aspects of data-driven businesses. Considering the above, this article first discusses the background of value chain analysis and its commonly used methods for transfer pricing purposes. Second, it attempts to establish a link between the concept of value creation in the data economy and the evolving data-driven business models and examines possible value chain analyses that might be able to describe these models properly. As an interim conclusion, the authors express the need for an adjustment of the current value chain analysis for digital/data-driven businesses, as it fails to integrate the ways in which the digital data ecosystem works. Therefore, for business models that rely heavily on data and for transactions that are data-intense/data-driven, the authors propose a quantitative approach, whereby the residual profit is attributed not only to profit and investment centres, but also to data function. As it is crucial for such a value chain analysis to appropriately reflect value creation, the authors also propose a framework of digital documentation tools to understand the economic reasoning behind those businesses.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation Actions 8 10 2015 Final Reports written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 190 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Actions 8-10.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation Actions 8 10 2015 Final Reports written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-19 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
Download or read book Is Big Data that Simple An Analysis of the Transfer Pricing Aspects of Value Creation of Data in the Digitalized Economy written by Victor S. Calijuri and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Data steers the digitalized economy. The transformation of data into valuable information is somewhat comparable with traditional research and development activities and has become one of the most valuable intangibles for many companies. The knowledge discovery method in databases, known as “data mining”, needs to be studied conceptually to demonstrate that the arm's length principle cannot effectively allocate profits to jurisdictions. Nevertheless, much effort has been put into OECD's Pillar One, but is it indeed ready to deal with the big data economy? To answer this question, the author briefly introduces the evolution of transfer pricing and presents that the dichotomy between the arm's length principle comparability completeness and the formulaic apportionment simplicity were merged to create a more robust system to tackle the challenges of the digitalization and lack of physical presence. In a data-driven economy, it is essential to understand the steps involved in the value creation of data. The purpose of the present study is to meticulously delineate the value chain of big data, including collection, processing and analysis and monetization of the data. In conclusion, the author suggests a framework that effectively allocates profits in accordance with the value creation of data.
Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi and published by . This book was released on 2019 with total page 556 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Impacts of Transfer Pricing on Value Creation written by Hubertus Bernardus Antonius Steens and published by . This book was released on 2008 with total page 192 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi and published by Linde Verlag GmbH. This book was released on 2019-09-02 with total page 572 pages. Available in PDF, EPUB and Kindle. Book excerpt: Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Download or read book From Compliance to the C suite Value Creation Analysed Through the Transfer Pricing Lens written by I. Verlinden and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Business models in a global context have evolved at a much speedier pace than the international tax framework. The internet of things, powerful corporate identities, innovative ways to play the market and an increasing reliance on intangibles are vital elements that lead to unprecedented ways of 'value creation'. The base erosion and profit shifting (BEPS) project by the OECD/G20 aims at ensuring that profits are effectively taxed where the economic activities generating the profits are performed. This is embedded in the premise that transfer pricing outcomes should be aligned with value creation. Many tax authorities and tax practitioners grapple with interpreting and translating value creation under innovative business models of multinational enterprises (MNEs) to the transfer pricing dictionary. In this article, the authors describe by means of examples how successful companies nowadays create value and unlock 'economic rent' across the value chain based on distinctive capabilities and unique business models. The authors subsequently put forward a novel economic approach to grasp value creation from a tax perspective in order to test whether there is a match with the transfer pricing outcomes.
Download or read book Value Chain Analysis the BEPS Version of Transfer Pricing written by Marina Menezes and published by . This book was released on 2019-05-28 with total page 27 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the holistic transfer pricing approach that a number of countries have been implementing into their laws following the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative. In this context, a value chain analysis (VCA) approach aligns business models, finance and tax positions and the governance of multinational enterprises (MNEs) with best practice under the OECD/G20 BEPS initiative.
Download or read book Fundamentals of Transfer Pricing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2022-06-20 with total page 549 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing’s interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.
Download or read book Taxation and Value Creation written by Werner C. Haslehner and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework
Download or read book OECD G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Aspects of Intangibles written by OECD and published by OECD Publishing. This book was released on 2014-09-16 with total page 134 pages. Available in PDF, EPUB and Kindle. Book excerpt: This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles.
Download or read book Transfer Pricing and Intangibles written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2019-04-11 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.
Download or read book The Use of Value Chain Analysis in a Profit Split written by C. Bagran Ilhan and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article provides an introduction to the profit split method (PSM), giving a quick look into its evolution throughout time and explaining how it shall be identified and applied as the most appropriate transfer pricing method, while demystifying the terms "value creation" and "value chain analysis" (VCA) and explaining why they were introduced by the OECD in the Action Plan on Base Erosion and Profit Shifting (BEPS) Actions. The article elaborates on what a VCA should consider, how it should be conducted and what should be the outcome, and addresses the practical aspects of the use of the PSM in a VCA, based on a numerical example in the light of the OECD's recommendations in, inter alia, the OECD Model Tax Convention, the OECD Transfer Pricing Guidelines, the BEPS Actions, discussion drafts and public consultations on the application of the PSM.
