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Transfer Pricing And The Arm S Length Principle In International Tax Law

Author: Jens Wittendorff
Publisher: Kluwer Law International B.V.
ISBN: 9041132708
Size: 55.67 MB
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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.

International Taxation Of Permanent Establishments

Author: Michael Kobetsky
Publisher: Cambridge University Press
ISBN: 1139500228
Size: 23.32 MB
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The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.

The International Taxation System

Author: Andrew Lymer
Publisher: Springer Science & Business Media
ISBN: 9781402071577
Size: 66.62 MB
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International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.

Resolving Transfer Pricing Disputes

Author: Eduardo Baistrocchi
Publisher: Cambridge University Press
ISBN: 1139916289
Size: 10.61 MB
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Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

Fundamentals Of International Transfer Pricing In Law And Economics

Author: Wolfgang Schön
Publisher: Springer Science & Business Media
ISBN: 3642259804
Size: 53.72 MB
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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.

The Transfer Pricing Of Intangibles

Author: Michelle Markham
Publisher: Kluwer Law International B.V.
ISBN: 9041123687
Size: 32.38 MB
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Transactions involving intellectual property play an increasingly significant role in economic activity at every level from global to local, with particular challenges for taxation and revenue authorities. Moreover, the manifold complexities associated with identifying, valuing and transferring intangibles make this an issue requiring a creative review of existing transfer pricing methodologies and techniques. In this ground-breaking new study, Michelle Markham offers an in-depth examination of attitudes at the forefront of this rapidly evolving area of taxation law, focusing her work on a comparative analysis of the US, OECD, and Australian perspectives on the transfer pricing of intangible assets. The Transfer Pricing of Intangibles not only highlights the current problems encountered in inter-affiliate transactions of intangible property, but also attempts to offer a variety of solutions to these problems. Among the issues explored are the following: how the tax treatment of intangible in the context of transfer pricing has become a major international tax concern;definitional issues which are vital to an understanding of transfer pricing;application of the arm's length principle to intangible asset transactions;determination of legal and economic ownership of group intangible assets;intangible asset valuation and transfer;transfer pricing methodologies;global formulary apportionment;transfer pricing documentation requirements;penalties for non-compliance;resolution of transfer pricing disputes; and,advance pricing agreements Revenue authorities, multinational enterprise executives, and tax practitioners around the world will greatly appreciate the recommendations and solutions proposed in this knowledgeable and thoughtful book. Its acute sense of the opportunities and pitfalls of an ever-more-complex area of economic activity place it in a category of its own, of inestimable benefit to interested parties.

Federal Tax Research

Author: Roby Sawyers
Publisher: Cengage Learning
ISBN: 130517769X
Size: 59.96 MB
Format: PDF
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This market-leading tax research text takes a practical, hands-on approach that goes beyond a random sampling of tax research sources. Fully updated, FEDERAL TAX RESEARCH extensively covers technology-oriented research tools. From its tax planning orientation to real-life cases, this is one book that conveys a true understanding of the most important elements of the federal tax law. Important Notice: Media content referenced within the product description or the product text may not be available in the ebook version.

Taxation In A Global Digital Economy

Author: Ina Kerschner
Publisher: Linde Verlag GmbH
ISBN: 3709409047
Size: 33.20 MB
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Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.

International Financial Management

Author: Jeff Madura
Publisher: Cengage Learning
ISBN: 0538482966
Size: 37.36 MB
Format: PDF, Kindle
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Prepare for success in international finance with this best-selling book’s effective presentation of in-depth theory and practical applications. INTERNATIONAL FINANCIAL MANAGEMENT, 11E builds on the fundamental principles of corporate finance to provide the timely information and contemporary insights needed to prosper in today’s global business environment. This book discusses a wide range of managerial topics using a strong corporate perspective. This edition highlights financial reform and its impact on the international finance today. An emphasis on the most recent financial changes and industry trends further prepares readers to understand and effectively manage within the dynamic field of international finance. Important Notice: Media content referenced within the product description or the product text may not be available in the ebook version.