Transfer Pricing Answer

Author: David B. Blair

Publisher: N.A

ISBN: 9781402426162

Category: Law

Page: 692

View: 2529

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The phenomena of increasingly global business enterprises with valuable intangible property expose companies to transfer pricing enforcement by different countries around the world. Many of these countries are increasingly aggressive in enforcing their local transfer pricing rules, as they attempt to protect their tax revenue base. To avoid double taxation of the same income in this environment, companies often are required to deal with the highly specialized, bilateral treaty-based competent authority process developed to prevent double taxation at a time when trade mainly involved only two established countries. Even more challenging today, companies and tax authorities increasingly are faced with the potential for multiple taxation of the same income, as supply chains cross many borders and as the tax authorities of emerging countries become players in the global taxation process, and the resulting stresses, strains, and limitations of the bilateral treaty-based competent authority process have become more apparent. In light of the high-dollar risks presented by the increased enforcement efforts of tax authorities worldwide, the complexity of the ever-changing, inherently uncertain transfer pricing standards, and the continually evolving business models of businesses adapting to the constantly changing global economy, companies need practical guidance to permit them to develop and defend their transfer pricing strategies. Transfer Pricing Answer Book 2016 gives companies such guidance by discussing all aspects of transfer pricing, from initially planning a transfer pricing strategy, to alternative ways to defend the strategy from attack by two or more tax authorities, to resolving a case before competent authorities, to bringing a transfer pricing case to court. The book s non-technical discussion is presented in a question and answer format that will appeal to readers regardless of their prior level of experience or familiarity with taxes in general and transfer pricing in particular. Transfer Pricing Answer Book 2016 is an invaluable resource for company executives and their advisors who are seeking to better understand this important area of tax law that has become such an important economic facet of so many businesses."
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Transfer Pricing Developments Around the World 2018

Author: Michael Lang,Alfred Storck,Raffaele Petruzzi

Publisher: Kluwer Law International B.V.

ISBN: 9041195653

Category: Law

Page: 248

View: 6894

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Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the 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), this book offers seven topic-based papers prepared by international experts on transfer pricing. Greatly helping to define where the line should be drawn to distinguish genuine transfer pricing issues from other anti-avoidance measures, this book encompasses the following topics: • global transfer pricing developments; • transfer pricing developments in the European Union; • transfer pricing developments in the United States; • transfer pricing developments in developing countries and emerging economies; • recent developments on transfer pricing documentation and country-by-country reporting; • recent developments on comparability analysis in transfer pricing; and • recent developments on the profit split method. The intense work of international organizations such as the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund, and other international organizations is thoroughly analyzed in this book. The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating an efficient dialogue and coordinated approach to transfer pricing in the future.
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Recent Trends In Transfer Pricing Intangibles, GAAR and BEPS

Author: Ravikant Gupta

Publisher: Bloomsbury Publishing

ISBN: 938614171X

Category: Business & Economics

Page: 532

View: 7674

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About the book The growing importance of the intangible assets in the global economy coupled with expanding international intra-firm trade, has meant that transfer pricing issues concerning intangibles have assumed critical importance for both the Multi National Enterprises as well as Tax authorities. The identification, accounting & valuation of intangibles is a challenging and evolving field. This volume details the various such issues and concerns from both industry and revenue perspective. Further, the contemporary issues of digital economy, tax planning, BEPS, GAAR have also been extensively dealt with. Key features · Explains in detail the meaning of various types of intangibles as defined in Income Tax Act. · Discusses the various possible methodologies for valuing the intangibles including the typical and residual methods · Accounts for all the relevant changes suggested by the OECD in the BEPS Action Point 8-10 report regarding intangibles · Valuation of Highly Uncertain as well Hard-to-Value Intangibles · Relevant Features of and taxation challenges posed by Digital economy · Various possible techniques of Tax Planning adopted by the Multi-national Enterprises · All the BEPS Action Point Reports along with recommendations as adopted globally as well as in India including Thin Capitalisation, PoEM, Equalisation Levy, amended DTAAs with Mauritius, Cyprus & Singapore {Updated upto Finance Bill, 2017 (India)} · Transfer Pricing Aspects of CCAs, Intra-group Services & Business Restructuring including issue of indirect transfers · Discussion on General Anti Avoidance Rules, to be implemented in India from 01/04/2017 · Famous and important global and Indian case laws with regard to intangibles · Detailed discussion on issue of AMP expenses & marketing intangibles
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Transfer Pricing in a Post-BEPS World

Author: Michael Lang,Alfred Storck

Publisher: Kluwer Law International B.V.

ISBN: 9041167129

Category: Law

Page: 242

View: 1677

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The OECD’s Base Erosion and Profit Shifting (BEPS) project promises to make effective inroads into the much criticized corporate tax strategy known as aggressive transfer pricing, whereby the profitability of subsidiaries in different jurisdictions is “managed” via mispricing with the intent of minimizing the corporation’s overall tax burden. Although the OECD BEPS project is an ongoing endeavor, its accomplishments to date and developing trends are discernible. This book, including contributions by outstanding and renowned transfer pricing experts both from practice and academia, analyses these trends, and proposes reforms which would ensure that transfer pricing outcomes are better aligned with economic activities and value creation, which achieves a more equitable distribution of profits among different countries. Each chapter is dedicated to specific sections of the OECD’s BEPS Action Plan. Among the topics and issues covered are the following: – arm’s length principle and its ongoing development; – allocation of risk and recharacterization; – intangibles (both license model and cost contribution arrangements); – interest deductions and intra-group financing; – low value-adding services; – commissionaire arrangements and low-risk distributors; – attribution of profits to permanent establishments; – documentation requirements (including Country-by-Country Reporting). Within these topics, measures to identify the commercial and financial relationships inside multinational enterprises, to accurately delineate actual transactions, as well as guidance on defining risk and its allocation among entities of a multinational enterprise are discussed. The book is based on papers presented and discussed at the first Global Transfer Pricing Conference hosted in February 2016 by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business). The most up-to-date and thorough consideration of transfer pricing yet published, this book will prove invaluable for all parties currently facing questions related to transfer pricing in a post-BEPS world, especially those in charge of finding an ideal answer to them: academics, practitioners (including in-house and advisory counsel), international organizations, CEOs and CFOs of multinational enterprises, and government officials who are tax and transfer pricing experts.
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Asset Liability Management / Gesamtbanksteuerung

Handbuch / Handbook

Author: Hannes Enthofer,Patrick Haas

Publisher: Linde Verlag GmbH

ISBN: 3709407222

Category: Law

Page: 1352

View: 2254

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Alle ALM-Aktivitäten in einem Band Dieses neue Standardwerk zeigt die praktische Umsetzung des Asset Liability Managements/der Gesamtbanksteuerung unter den neuen gesetzlichen Rahmenbedingungen von Basel III und den aktuellen EU-Richtlinien. Themen sind u.a. die Bankbuchsteuerung im Rahmen des ICAAP, Eigenkapital und Risiko-/Ertragssteuerung in der Gesamtbank und der Einsatz von Finanzinstrumenten im ALM und Hedging von Risikopositionen bis hin zu Corporate Governance & Compliance auf Gesamtbankebene zur Erfüllung der regulatorischen Anforderungen.
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A Very Short, Fairly Interesting and Reasonably Cheap Book about International Business

Author: George Cairns,Martyna Sliwa

Publisher: SAGE

ISBN: 1526414945

Category: Business & Economics

Page: 176

View: 9550

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Conceived by Chris Grey as an antidote to conventional textbooks, each book in the ‘Very Short, Fairly Interesting and Reasonably Cheap’ series takes a core area of the curriculum and turns it on its head by providing a critical and sophisticated overview of the key issues and debates in an informal, conversational and often humorous way. The Second Edition of International Business includes recent impacts on international business such as the financial crisis, Brexit and the changing political landscape, Chinese steel prices and the Panama Papers revelations. It includes two new chapters on understanding people and organizations in International Business as well as coverage of recent international reports from Amnesty, Oxfam and the World Bank. Suitable for students of International Business, professionals working in global organizations and anyone curious about the workings of the international business world.
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Winning the Tax Wars

Tax Competition and Cooperation

Author: Brigitte Alepin,Blanca Moreno-Dodson,Louise Otis

Publisher: Kluwer Law International B.V.

ISBN: 9041194614

Category: Law

Page: 208

View: 2616

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Over the past few decades, the concentration of wealth and property in the hands of a few has been facilitated by tax evasion, tax avoidance, and above all by tax competition. Fortunately, a determined move toward international cooperation among tax authorities is gathering its forces to do battle. This invaluable book shows how the globalization of trade, the digitization of the economy, tax competition between sovereign states, the erosion of the tax base, and the transfer of pro ts have all revealed the weaknesses of a traditional tax system that has reached its limits, and how numerous states and groups of states have joined efforts in creating a new international tax system designed to restore fairness and stability in the levying of taxes worldwide. Stemming from a 2016 conference initiated by the Canadian non-pro t organization TaxCOOP, convened by the World Bank and bringing together well-known taxation experts from prominent international organizations, the book presents outstanding contributions highlighting the impacts of tax competition and viable solutions. Among the issues and topics covered are the following: – electronic commerce and electronic money; – transfer pricing; – derivatives and hedge funds; – protecting tax whistle-blowers; – offshore tax investigations; – possibility of an international tax court; – impact of tax competition on developing countries; – carbon pricing; – tobacco taxation; and – effective taxation of the ultra-wealthy and their nancial capital. The chapters include details of country experiences and results, in some cases analyzed by key protagonists themselves. Collectively, the contributions take a giant step toward reinforcing the power of sovereign states in sectors such as the environment, education, and health. As an authoritative guide to increasing the level of transparency and accountability of private and public economic actors and restoring citizens’ trust in the fairness of our global governance systems, this peerless volume will be warmly welcomed by tax lawyers, taxation authorities, and interested academics worldwide.
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Product Cost Controlling with SAP

Author: John Jordan

Publisher: SAP PRESS

ISBN: 9781592293995

Category: Computers

Page: 625

View: 4901

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Learn how product costing works and integrates with other modules Master integrated planning, product cost planning, manufacturing methods, reporting, and more Reduce long run times during month-end processing and streamline controlling processes Run your business more transparently and effectively: use this updated reference and configuration guide to learn about product cost planning, cost object controlling, and integrated planning. Easy-to-understand process overviews and configuration setup requirements will help you customize product cost controlling to your business needs. Find answers to your questions about the material ledger, transfer pricing, and reporting, learn how to address common problem areas, and much more. This is the one resource you need to learn how Product Cost Controlling works in SAP ERP Financials. Breadth and Depth This book both explains the business concepts of product costing and teaches you how to master and benefit from Product Cost Controlling with SAP. A Lesson in Configuration Learn to let Product Cost Controlling shine by integrating it smoothly into your business and configuring it based on your specific business requirements.Examples Abound This book features practical examples and case studies that will help you reinforce your understanding of the topics addressed. Coverage of Special Topics New content addresses special topics that will arise in your work, such as subcontracting, activity-based costing, sales order controlling, and mixed-cost estimates. Updated and Expanded This second edition expands coverage of integrated planning and master data, among other topics, and adds sections on information system, settlement, and more.
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Encyclopedic Dictionary of International Finance and Banking

Author: Jae K. Shim,Michael Constas

Publisher: CRC Press

ISBN: 1420025597

Category: Business & Economics

Page: 336

View: 9007

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The Encyclopedic Dictionary of International Finance and Banking is a practical reference of proven techniques, strategies, and approaches. It covers virtually all important topics dealing with multinational business finance, money, investments, financial planning, financial economics, and banking. In addition, it explores the application of computers, quantitative techniques and models, and economics to international finance and banking. You get: Clear definitions and explanations Step-by-step instructions Statistical data, Charts, exhibits, and diagrams Checklists Practical Applications Shim presents the most current information, offers important directives, and explains the technical procedures involved in this dynamic field. This reference gives you the tools you need to diagnose and evaluate the financial situations you face on a daily basis and answers every question you may have. It provides real-life examples and suggestions for handling everyday problems. WHAT THIS BOOK WILL DO FOR YOU More than a dictionary, more than an encyclopedia, this working guide will help you quickly pinpoint: What to look for How to do it What to watch out for How to apply it in the complex world of business What to do You'll find ratios, formulas, examples, applications, exhibits, charts, and rules of thumb to help you analyze and evaluate any multinational financial decision. You will find this Encyclopedic Dictionary practical, comprehensive, quick, and useful. In short, this is a veritable cookbook of guidelines, illustrations, and how-tos. Encyclopedic Dictionary of International Finance and Banking is the resource you will reach for again and again.
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