Fundamentals Of Transfer Pricing
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Fundamentals of Transfer Pricing
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. In analysing the 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.
Fundamentals of International Transfer Pricing in Law and Economics
Author: Wolfgang Schön
language: en
Publisher: Springer Science & Business Media
Release Date: 2012-02-15
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.
Fundamentals of Transfer Pricing
Author: Raffaele Petruzzi
language: en
Publisher: Kluwer Law International B.V.
Release Date: 2022-06-20
This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing’s interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.