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Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies 6th ed

Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies 6th ed

  • 作者:
  • 出版商: Kluwer Law International
  • ISBN: 9789041169082
  • Previous Edition ISBN: 9789041161246
  • 出版时间 September 2016
  • 规格: Paperback
  • 适应领域: Netherlands ? 免责申明:
    Countri(es) stated herein are used as reference only
New Edition is available now !
  • 描述 
  • 大纲 
  • 详细

    In Guide to International Transfer Pricing, global practitioners address both the general issues that surround transfer pricing, including the Organisation for Economic Co-operation of Development’s (OECD) fifteen-item Base Erosion and Profit Shifting (BEPS) plan and the specific rules and issues that any company must concern itself with in various jurisdictions around the world. Tax authorities around the globe are increasingly scrutinizing the intercompany pricing practices of taxpayers and enacting rules and regulations to ensure an appropriate allocation of income among the various tax jurisdictions in which a multinational company operates. In addition, a growing number of tax authorities have established documentation requirements to demonstrate appropriate transfer pricing policies, with penalty provisions for non-compliance. Not only must a multinational company understand the different nuances in the transfer pricing laws and their practical interpretation in each local country, but it must also appreciate that by operating in jurisdictions with varying tax rates, transactional structures or intercompany pricing policies can impact the multinational’s global effective tax rate.

    What’s in this book:

    This guide is a collaboration of many transfer pricing experts from around the world with experience gained from assisting multinationals in implementing planning and compliance strategies, and their insights into dealing with local tax authorities. Key features of this book include:

    • overview of fundamental concepts applied in transfer pricing;
    • country-specific profiles that compare and contrast rules and real-world applications over multiple jurisdictions, including those likely to adopt BEPS; and
    • practical guidance and implementation, enabling the reader to execute a coordinated, cost-effective approach to global policies and documentation needs.
    How this will help you:

    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. The primary objective of this book is to arm the constituents impacted by transfer pricing, including tax directors, legal counsel, accounting and operations personnel, CFOs and outside advisors, with the knowledge base and resources needed for effective transfer pricing decision-making.

  • Editors
    Contributors
    List of Abbreviations
    Preface

    CHAPTER 1 Overview/Best Practices
    Michelle Johnson, Justin Radziewicz & Uday Singh
    CHAPTER 2 OECD Transfer Pricing Guidelines
    Andrew Cousins & Danny Beeton
    CHAPTER 3 Argentina
    Matías Federico Lozano & Cristian E. Rosso Alba
    CHAPTER 4 Australia
    Shannon Smit & Adriana Calderon
    CHAPTER 5 Belgium
    Natalie Reypens
    CHAPTER 6 Brazil
    Luís Rogério Farinelli, Cristiane M.S. Magalhães, Stephanie Makin & Amanda Alves Brandão.
    CHAPTER 7 Canada
    Jennifer Shulman
    CHAPTER 8 China
    Glenn DeSouza
    CHAPTER 9 France
    Félicie Bonnet & Arnaud Le Boulanger
    CHAPTER 10 Germany
    Angelika Thies
    CHAPTER 11 Ireland
    Joe Duffy & Barry McGettrick
    CHAPTER 12 Israel
    Jonathan Lubick
    CHAPTER 13 Italy
    Marco Valdonio, Aurelio Massimiano & Mirko Severi
    CHAPTER 14 Mexico
    Yoshio Uehara & Gustavo Méndez
    CHAPTER 15 The Netherlands
    Rogier Sterk & Patrick van Oppen
    CHAPTER 16 South Korea
    Tae Yeon (TY) Nam, Jae Suk (JS) Park & Christopher Sung
    CHAPTER 17 United Kingdom
    Shiv Mahalingham
    CHAPTER 18 United States
    Jill Weise, Stefanie Perrella & Rod Koborsi

    Annexes
    ANNEX I Transfer Pricing Rules Summary
    ANNEX II Transfer Pricing Implementation Checklist
    Table of Cases
    Index

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