Author : David Rosenbloom
Publisher :
Page : pages
File Size : 19,77 MB
Release : 2015
Category : Dispute resolution (Law)
ISBN :
Consists of the first three chapters of the 2011 edition which have been updated based on information available up to 15 September, 1 August, and 31 July 2014, respectively.
Author : Anuschka Bakker
Publisher : IBFD
Page : 807 pages
File Size : 41,62 MB
Release : 2011
Category : Dispute resolution (Law).
ISBN : 9087221002
This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.
Author : David Rüll
Publisher : Kluwer Law International B.V.
Page : 263 pages
File Size : 13,45 MB
Release : 2024-06-10
Category : Law
ISBN : 9403520981
The number of international tax disputes is constantly increasing. This is a logical consequence of the pressure that is exerted on the global tax system by a rise in the number of internationally active and mobile taxpayers and tax competition between states on the one hand. On the other hand, the implementation of measures to tackle base erosion and profit shifting (BEPS) by multinational enterprises already gives rise to further disputes and another increase of disputes might arise from the latest reforms of the international tax system, namely the Two-Pillar-Solution to address the tax challenges arising from the digitalisation of the economy. Against this background, the time is right for an institutionalised international tax dispute resolution mechanism that takes into account the interests of taxpayers, states, and the public and allows for a swift and binding resolution of international tax disputes ¬– exactly what this timely and thoroughgoing book offers. A comprehensive overview of existing international tax dispute resolution mechanisms – and an analysis of their procedural rules, advantages, and disadvantages – leads to a deeply informed proposal on how they can be further developed in a way that ensures greater fairness and equity for all stakeholders. Among the lines of conflict that characterise international tax disputes, the author sheds clear light on how improvements in the design of dispute resolution mechanisms may be found. This includes these questions: How should a dispute resolution mechanism be structured? Should there be a mandatory resolution if the states cannot agree? In which way should taxpayers participate in the procedure? Should agreements and decisions be published? Should there be an institution to administer the procedure? The book concludes with a draft convention that would implement the author’s suggestions. Tax lawyers and other tax professionals worldwide, as well as national tax authorities, will benefit greatly from this book. They will deepen their understanding of the variety of existing tax dispute resolution mechanisms and discover ways to strengthen them. Academics will find ample room to reflect on the key design elements of such mechanisms and how to improve them.
Author : American Bar Association. House of Delegates
Publisher : American Bar Association
Page : 216 pages
File Size : 23,69 MB
Release : 2007
Category : Law
ISBN : 9781590318737
The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Author : Anuschka Bakker
Publisher : IBFD
Page : 525 pages
File Size : 43,10 MB
Release : 2009
Category : Corporate reorganizations
ISBN : 9087220553
This book highlights the main tax issues that arise when business restructurings take place. It provides fundamental information about the drivers of business restructurings and business models, examines the application of Art. 9 of the OECD Model Convention, and considers not only the direct tax issues in business restructuring, but also VAT and customs duties. It gives practical insights into the tax accounting treatment of business restructurings, OECD work in progress and the effect of the EU tax system, and includes a case study concerning the restructuring of a manufacturing operation, which is analysed from the perspective of key industrial jurisdictions, along with an examination of current practice.
Author : United Nations
Publisher :
Page : 672 pages
File Size : 33,71 MB
Release : 2017
Category : Business & Economics
ISBN :
The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.
Author : Steve Edge
Publisher :
Page : 0 pages
File Size : 42,23 MB
Release : 2023
Category :
ISBN : 9781804491782
Author : Jeffrey R. Greene
Publisher : John Wiley & Sons
Page : 216 pages
File Size : 43,8 MB
Release : 2018-08-28
Category : Business & Economics
ISBN : 1119418135
Future-proof your business today for stronger performance tomorrow The Stress Test Every Business Needs: A Capital Agenda for Confidently Facing Digital Disruption, Difficult Investors, Recessions and Geopolitical Threats provides a comprehensive approach to creating value and flexibility in an increasingly volatile business environment that presents both great risks and opportunities every day. The authors extend the banking “stress test” concept to a company’s Capital Agenda — how executives manage capital, execute transactions and apply corporate finance tools to strategic and operational decisions. Having a static Capital Agenda, however appropriate for your current market position, is not enough in today's uncertain world. Long-term success comes from building resilience into each element and in the way those elements interact. The book uses a broader definition of business stress that includes traditional macroeconomic and geopolitical risks, as well as technological disruption, hostile takeovers and activist shareholders. Companies that make poor strategic decisions or underperform operationally will likely find themselves facing great stress. And that stress is symmetric; threats come from downside risks and from missed opportunities. The chapters address the how and why of essential issues such as: Formulating corporate strategy in a digital world Pre-empting activist shareholders Restoring distressed companies to operational and financial health Ensuring effective collaboration among strategy, finance and operations Getting the most out of your advisors Proactively managing intrinsic value Rigorously allocating capital across the enterprise Acquiring and divesting for optimum value Syncing financing decisions with business strategy and capital market conditions Incorporating tax planning throughout the Capital Agenda Liberating excess cash with leading working capital management practices Aligning strategic goals and metrics to reach your company’s full potential Companies that develop strategy and set operational priorities with a balanced Capital Agenda are best positioned to control their own destiny. The Stress Test Every Business Needs provides a roadmap to future-proof your business today for stronger performance tomorrow.
Author : OECD
Publisher : Org. for Economic Cooperation & Development
Page : 186 pages
File Size : 11,84 MB
Release : 2015-10-19
Category :
ISBN : 9789264241237
The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
Author : OECD
Publisher : OECD Publishing
Page : 612 pages
File Size : 47,97 MB
Release : 2017-07-10
Category :
ISBN : 9264265120
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.
