Introduction to Transfer Pricing, 2nd Edition

作者： Jérôme Monsenego
出版商： Kluwer Law International
ISBN: 9789403514833
出版时间 December 2022
规格： Hardback
适应领域： International ? 免责申明：
Countri(es) stated herein are used as reference only

List Price: ￥1,162.50

￥1,127.63 Save ￥34.88 (3%)

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About this book:

Introduction to Transfer Pricing, currently in its second edition, is a book that intends to introduce the fundamentals of transfer pricing. Although the book relies mainly on the OECD Transfer Pricing Guidelines, the views of other international organisations – in particular, the United Nations and the European Union – are also considered. In addition, the book illustrates the fundamentals of transfer pricing with concrete examples based on the business models often used by multinational enterprises. Relevant court cases from various countries are also included.

A foreword to this book is provided by Prof. Michael Lang.

What’s in this book:

The following issues and topics have been discussed in this book:
- the arm’s length principle in theory and practice;
- transfer pricing methods;
- intercompany transactions involving intangibles and financial transactions;
- common types of transfer pricing models;
- cross-border business restructurings;
- the substance requirement for transfer pricing purposes;
- attribution of profits to permanent establishments; and
- the prevention and resolution of transfer pricing disputes.
- This second edition was updated based on the 2022 OECD Transfer Pricing Guidelines and the 2021 UN Transfer Pricing Manual.
How this will help you:

This timely book provides an easily accessible yet deep enough introduction to one of the most important international tax issues for multinational enterprises and tax administrations. The book will be of great use for students, practitioners, government officials and judges.
About the Author

List of Abbreviations

List of Figures

List of Tables

Foreword

Preface to the Second Edition

Preface to the First Edition

Introduction

CHAPTER 1

The Key to Understanding Transfer Pricing: The Arm’s Length Principle

CHAPTER 2

Transfer Pricing Methods

CHAPTER 3

Transfer Pricing Models

CHAPTER 4

Cross-Border Business Restructurings

CHAPTER 5

The Substance Requirement from a Transfer Pricing Perspective

CHAPTER 6

The Attribution of Profits to Permanent Establishments

CHAPTER 7

Administrative Aspects: Compliance Issues and Transfer Pricing Disputes

Bibliography

Table of Cases

Table of Legislation

Index

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