Description: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 Part General Topics
I. Introduction to Transfer Pricing
II. Accurate Delineation and Recognition of Actual 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 Master File, Country File and Country-by-Country Reporting
Part 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.We have made it easy for you to find a PDF Ebooks without any digging. And by having access to our ebooks online or by storing it on your computer, you have convenient answers with Fundamentals of Transfer Pricing: A Practical Guide. To get started finding Fundamentals of Transfer Pricing: A Practical Guide, you are right to find our website which has a comprehensive collection of manuals listed. Our library is the biggest of these that have literally hundreds of thousands of different products represented.
Pages
550
Format
PDF, EPUB & Kindle Edition
Publisher
Kluwer Law International
Release
2018
ISBN
904119021X
Fundamentals of Transfer Pricing: A Practical Guide
Description: 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 Part General Topics
I. Introduction to Transfer Pricing
II. Accurate Delineation and Recognition of Actual 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 Master File, Country File and Country-by-Country Reporting
Part 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.We have made it easy for you to find a PDF Ebooks without any digging. And by having access to our ebooks online or by storing it on your computer, you have convenient answers with Fundamentals of Transfer Pricing: A Practical Guide. To get started finding Fundamentals of Transfer Pricing: A Practical Guide, you are right to find our website which has a comprehensive collection of manuals listed. Our library is the biggest of these that have literally hundreds of thousands of different products represented.