Download or read book Transfer Pricing Handbook 2 Volume Set 1999 Cumulative Supplement written by Robert Feinschreiber and published by Wiley. This book was released on 1999-09-16 with total page 446 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is the sale, license, or lease of a product from one affiliated company to another. This book takes an international viewpoint and examines U.S. companies doing business abroad as well as foreign-owned corporations. It answers all questions on the often complex issue of transfer pricing. The final treasury regulations on transfer pricing (Section 482) affect all corporations that import and export from their subsidiaries, heavily influencing the value they place on their goods. This clear-cut guide helps corporations to understand and capitalize on the new regulations in order to save up to 39% on their taxes.

Download or read book Transfer Pricing Handbook 2 Volume Set 1999 Supplement written by Robert Feinschreiber and published by Wiley. This book was released on 1999-03-12 with total page 351 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is the sale, license, or lease of a product from one affiliated company to another. This book takes an international viewpoint and examines U.S. companies doing business abroad as well as foreign-owned corporations. It answers all questions on the often complex issue of transfer pricing. The final treasury regulations on transfer pricing (Section 482) affect all corporations that import and export from their subsidiaries, heavily influencing the value they place on their goods. This clear-cut guide helps corporations to understand and capitalize on the new regulations in order to save up to 39% on their taxes.

Download or read book Transfer Pricing Handbook written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2001 with total page 878 pages. Available in PDF, EPUB and Kindle. Book excerpt: This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).

Download or read book Transfer Pricing Handbook 2 Volume Set 1998 Supplement written by Robert Feinschreiber and published by Wiley. This book was released on 1998-09-16 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is the sale, license, or lease of a product from one affiliated company to another. This book takes an international viewpoint and examines U.S. companies doing business abroad as well as foreign-owned corporations. It answers all questions on the often complex issue of transfer pricing. The final treasury regulations on transfer pricing (Section 482) affect all corporations that import and export from their subsidiaries, heavily influencing the value they place on their goods. This clear-cut guide helps corporations to understand and capitalize on the new regulations in order to save up to 39% on their taxes.

Download or read book Transfer Pricing Handbook 2 Volume Set written by Robert Feinschreiber and published by Wiley. This book was released on 2001-04-24 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This handbook provides a comprehensive analysis of the transfer pricing issues that affect taxpayers and tax collectors alike. It has a practical focus advising taxpayers about transfer pricing techniques and their consequences. * Provides non-tax transfer pricing guidance on such issues as imported merchandise, customs-related issues, and customs appraisement * Describes IRS penalties in detail * Describes various transfer pricing methodologies This core volume (ISBN 0471-406619) is supplemented annually. The 2002 Supplement includes updates to both Transfer Pricing 3e and Transfer Pricing International. It contains: * Two new chapters on Cost-Sharing Buy-Ins and Technology, Licensing, and Economic Issues in Transfer Pricing * Complete revisions to chapters on New Zealand, Singapore, Belgium, Czech Republic, Russia, and South Africa. (with updates to Germany chapter) * New Appendix containing information regarding Practice Note 7 This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).

Download or read book Transfer Pricing Handbook 1994 Supplement written by Robert Feinschreiber and published by Wiley. This book was released on 1994-04-11 with total page 127 pages. Available in PDF, EPUB and Kindle. Book excerpt: A contributed volume, based on the new transfer pricing Treasury regulations (Section 482), by international tax and accounting experts with extensive experience in this area. International corporations dealing with imported or exported products from their subsidiaries are affected by this new rule and those that do not comply will face strict penalties which can be financially damaging. Analyzes numerous aspects of transfer pricing including cost sharing, valuation of intangibles and priority regulations. The final section helps the taxpayer prepare for audits or litigation.

Download or read book Transfer Pricing Handbook 1995 Cumulative Supplement written by Robert Feinschreiber and published by Wiley. This book was released on 1995-10-02 with total page 321 pages. Available in PDF, EPUB and Kindle. Book excerpt: A contributed volume, based on the new transfer pricing Treasury regulations (Section 482), by international tax and accounting experts with extensive experience in this area. International corporations dealing with imported or exported products from their subsidiaries are affected by this new rule and those that do not comply will face strict penalties which can be financially damaging. Analyzes numerous aspects of transfer pricing including cost sharing, valuation of intangibles and priority regulations. The final section helps the taxpayer prepare for audits or litigation.

Download or read book Practical Guide to U S Transfer Pricing written by Robert T. Cole and published by Aspen Publishers. This book was released on 1999 with total page 1302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.

Download or read book Transfer Pricing Methods written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2004-03-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advanced praise for Transfer Pricing Methods "Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue." -Charles R. Goulding, Managing Director, Tax Cooper Industries, Inc. "It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses." -Vikram A. Gosain, JD, CPA, Director of Transfer Pricing General Electric Capital Corporation "This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants." -Joseph C. Mandarino, Partner Troutman Sanders, LLP "Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty." -Charles L. Crowley, Partner ITS/Customs and International Trade Practice, Ernst & Young, LLP "Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational." -Enrique MacGregor, Principal-in-Charge, Transfer Pricing Services Grant Thornton LLP "Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate." -Alan Getz, Vice President and General Manager, Tax Mitsui & Co., Inc. (U.S.A.) "Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner." -Per H. Hasenwinkle, National Practice Leader, Transfer Pricing BDO Seidman, LLP

Download or read book Transfer Pricing Handbook 2 Volume Set written by Robert Feinschreiber and published by Wiley. This book was released on 1997-12-23 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is the sale, license, or lease of a product from one affiliated company to another. This book takes an international viewpoint and examines U.S. companies doing business abroad as well as foreign-owned corporations. It answers all questions on the often complex issue of transfer pricing. The final treasury regulations on transfer pricing (Section 482) affect all corporations that import and export from their subsidiaries, heavily influencing the value they place on their goods. This clear-cut guide helps corporations to understand and capitalize on the new regulations in order to save up to 39% on their taxes.

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 Handbook written by and published by . This book was released on 1993 with total page 629 pages. Available in PDF, EPUB and Kindle. Book excerpt:

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 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.

Download or read book U S Transfer Pricing Sourcebook written by Amanda Johnson and published by WorldTrade Executive, Inc.. This book was released on 2005-03 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: U.S. TRANSFER PRICING SOURCEBOOK is a single-volume report designed to advise international finance professionals on the cutting edge tools and techniques being developed and applied by leading consultants. This sourcebook provides strategies on Intercompany Sales, Intercompany Service transactions, Cross-Border licensing, and Cost Sharing agreements.

Download or read book Transfer Pricing Handbook 2 Volume Set written by Robert Feinschreiber and published by Wiley. This book was released on 2001-04-24 with total page 1488 pages. Available in PDF, EPUB and Kindle. Book excerpt: This handbook provides a comprehensive analysis of the transfer pricing issues that affect taxpayers and tax collectors alike. It has a practical focus advising taxpayers about transfer pricing techniques and their consequences. * Provides non-tax transfer pricing guidance on such issues as imported merchandise, customs-related issues, and customs appraisement * Describes IRS penalties in detail * Describes various transfer pricing methodologies This core volume (ISBN 0471-406619) is supplemented annually. The 2002 Supplement includes updates to both Transfer Pricing 3e and Transfer Pricing International. It contains: * Two new chapters on Cost-Sharing Buy-Ins and Technology, Licensing, and Economic Issues in Transfer Pricing * Complete revisions to chapters on New Zealand, Singapore, Belgium, Czech Republic, Russia, and South Africa. (with updates to Germany chapter) * New Appendix containing information regarding Practice Note 7 This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).

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