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Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies, 8th Edition

Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies, 8th Edition

作者： Duff & Phelps
出版商： Kluwer Law International
ISBN: 9789403502922
出版时间 November 2018
规格： Paperback , 1206 pages
适应领域： Argentina, Australia, Belgium, Brazil, Canada, China, France, Germany, Hong Kong, Indonesia, International, Ireland, Israel, Italy, Malaysia, Mexico, Netherlands, Singapore, South Korea, Spain, U.K., U.S., Vietnam ? 免责申明：
Countri(es) stated herein are used as reference only

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Table Of Contents

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 & Jay Hudson

Chapter 2
OECD Transfer Pricing Guidelines
Andrew Cousins

Chapter 3
Argentina
Matías Federico Lozano & Cristian E. Rosso Alba

Chapter 4
Australia
Stean Hainsworth

Chapter 5
Belgium
Natalie Reypens

Chapter 6
Brazil
Luís Rogério Farinelli, Cristiane M.S. Magalhães, Stephanie Makin & Nathália Fraga

Chapter 7
Canada
Matt Billings

Chapter 8
China
Glenn DeSouza

Chapter 9
France
Serge Lambert & Arnaud Le Boulanger

Chapter 10
Germany
Angelika Thies

Chapter 11
Hong Kong
Steven Carey & Douglas Fone

Chapter 12
Indonesia
Douglas Fone & Steven Carey

Chapter 13
Ireland
Joe Duffy & Barry McGettrick

Chapter 14
Israel
Jonathan Lubick

Chapter 15
Italy
Marco Valdonio, Aurelio Massimiano & Mirko Severi

Chapter 16
Malaysia
Douglas Fone & Steven Carey

Chapter 17
Mexico
Yoshio Uehara

Chapter 18
The Netherlands
Rogier Sterk & Robert Jan van Lie Peters

Chapter 19
Singapore
Douglas Fone & Steven Carey

Chapter 20
South Korea
Tae Yeon (TY) Nam, Jae Suk (JS) Park & Christopher Sung

Chapter 21
Spain
Pilar Barriguete

Chapter 22
United Kingdom
Andrew Cousins, Daniel Othmann & Ted Keen

Chapter 23
United States
Jill Weise, Stefanie Perrella, Rod Koborsi & Jay Hudson

Chapter 24
Vietnam
Steven Carey, Tu Ha Anh & Douglas John Fone

Annexes

Annex I

Transfer Pricing Rules Summary

Annex II

Transfer Pricing Implementation Checklist

Table of Cases

Index

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