Author : OECD
Publisher : OECD Publishing
Page : 612 pages
File Size : 26,10 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.
Author : OECD
Publisher : OECD Publishing
Page : 658 pages
File Size : 44,35 MB
Release : 2022-01-20
Category :
ISBN : 9264921915
In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.
Author : Dr A. Michael Heimert
Publisher : Kluwer Law International B.V.
Page : 1074 pages
File Size : 34,15 MB
Release : 2018-10-26
Category : Law
ISBN : 9403501715
The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.
Author : Eduardo Baistrocchi
Publisher : Cambridge University Press
Page : 2216 pages
File Size : 30,25 MB
Release : 2017-08-17
Category : Law
ISBN : 1108150381
This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Author : OCDE,
Publisher : OCDE
Page : 70 pages
File Size : 41,73 MB
Release : 2015
Category : International business enterprises
ISBN : 9789264241466
This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports
Author : Business International Corporation
Publisher :
Page : 212 pages
File Size : 42,10 MB
Release : 1991
Category : Foreign exchange
ISBN :
A comprehensive guide to corporate practices in internal control and tax compliance. Included are case studies of how firms in a variety of industries approach transfer pricing.
Author : International Monetary Fund. Fiscal Affairs Dept.
Publisher : International Monetary Fund
Page : 82 pages
File Size : 20,84 MB
Release : 2012-08-16
Category : Business & Economics
ISBN : 1498340067
Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación
Author : Raffaele Petruzzi
Publisher : Linde Verlag GmbH
Page : 445 pages
File Size : 45,65 MB
Release : 2019-09-02
Category : Law
ISBN : 370941038X
Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Author : Christopher M. Blanchard
Publisher : DIANE Publishing
Page : 55 pages
File Size : 47,81 MB
Release : 2010-11
Category : History
ISBN : 1437928382
Contents: (1) Recent Developments; (2) Background: Saudi Arabia (SA)-U.S. Relations, 1931-2001; 9/11 and its Aftermath; Recent Assessments; Terrorist Financing; (3) Congress. Interest in SA: U.S. Foreign Assist. to SA and Prohibitions; Counter-terrorism Assist.; BAE Corruption Inquiry; (4) Current Issues in U.S.-SA Relations; Mil. Cooperation: Counterterrorism; Al Qaeda; Combating Extremism; Arab-Israeli Conflict; SA-Palestinian Relations; SA Policy Priorities in Iraq; U.S.-SA Trade; U.S. Oil Imports and SA Policy; SA Boycott of Israel and WTO Membership; Human Rights, Religious Freedom, and Political Reform; Leadership and Succession; Social Reform Debates and Recent Leadership Changes; Human Rights; Religious Freedom.
Author : Lorraine Eden
Publisher : University of Toronto Press
Page : 788 pages
File Size : 30,30 MB
Release : 1998-01-01
Category : Business & Economics
ISBN : 9780802007766
Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.
