Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations SET Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Binder 1999 Update written by OECD and published by OECD Publishing. This book was released on 1999-11-12 with total page 263 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 642 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.he OECD's BEPS project on the UN Model.

Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations SET Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Binder 1999 Update written by OECD and published by OECD Publishing. This book was released on 1999-11-12 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Bulletin for International Fiscal Documentation written by International Bureau of Fiscal Documentation and published by . This book was released on 1999 with total page 652 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations written by OECD and published by OECD Publishing. This book was released on 2017-07-31 with total page 192 pages. Available in PDF, EPUB and Kindle. Book excerpt:

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 74 pages. Available in PDF, EPUB and Kindle. Book excerpt: Includes 1999 update. 1998 update in back.

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 International Books in Print written by and published by . This book was released on 1998 with total page 1294 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2001 Travel version written by OECD and published by OECD Publishing. This book was released on 2001-06-26 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 2001 edition of Transfer Pricing Guidelines was substantially revised in July 2010. See the current edition. This compact version of Transfer Pricing Guidelines provides the complete and current text of the OECD pricing guidelines accepted by ...

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 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010 written by OECD and published by OECD Publishing. This book was released on 2010-08-16 with total page 375 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, the valuation, for tax purposes, of cross-border transactions between associated enterprises.

Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Update 1999 written by Organisation for Economic Co-operation and Development and published by OECD Publishing. This book was released on 1999 with total page 50 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations written by Oecd and published by Organization for Economic. This book was released on 1997-01-01 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

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 Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Update 1996 written by OECD and published by OECD Publishing. This book was released on 1996-04-17 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Yearbook of International Organizations written by Union of International Associations and published by . This book was released on 2001 with total page 1424 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book OECD transfer pricing guidelines for multinational enterprises and tax administrations written by Aurobindo Ponniah and published by . This book was released on 2013 with total page 760 pages. Available in PDF, EPUB and Kindle. Book excerpt: The increase in global trade and foreign direct investment has seen a large rise in companies operating across national borders. The growth of these multinational companies (MNCs) has been closely followed by the issue of inter-company transfer prices being used to reduce taxable profits. Today, transfer pricing is one of the most important issues facing MNCs as they attempt to fairly distribute their profits amongst each company in the group while dealing with tax authorities who are implementing transfer pricing regulations and strengthening enforcement in order to prevent a loss of revenue. The result of which is that transfer pricing controversies have become a major tax issue for companies