Transfer Pricing and Financing

作者： Raffaele Petruzzi; Michael Lang
出版商： Kluwer Law International
ISBN: 9789403540221
出版时间 March 2023
规格： Hardback
适应领域： International ? 免责申明：
Countri(es) stated herein are used as reference only

List Price: ￥1,236.90

￥1,199.79 Save ￥37.11 (3%)

或

下载订单表

加入收藏
| 加入比较

描述
大纲

详细
In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties.

Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions:
- loans;
- financial guarantees;
- cash pooling;
- hybrid financing;
- factoring;
- captive insurance; and
- asset management.
Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law.

Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.
Editors

Contributors

Preface

CHAPTER 1

Introduction

CHAPTER 2

Transfer pricing aspects of loans

Antonio Russo, Andre Dekker & Tim Böhne

CHAPTER 3

Transfer Pricing Aspects of Financial Guarantees

Andrew Hickman and Marcelo H. B. Moura

CHAPTER 4

Cash Pooling

CHAPTER 5

Hybrid Financing

CHAPTER 6

Transfer Pricing Aspects of Factoring

CHAPTER 7

Transfer Pricing Principles for Captive Insurance

Stanley J Hales & and Lucie Hovorkova

CHAPTER 8

Transfer Pricing Aspects of Asset Management

Dr. Georg Dettmann

Table of Cases

Index

你可能需要


The Hong Kong Company Secretary's Handbook: Practice and Procedure (11th Edition): List Price: ￥497.55

￥482.62 Save ￥14.93 (3%)


Hong Kong Tax & Accounting Practical Toolkit (Basic Package): ￥3,161.07


Hong Kong Master Tax Guide 2024/25 (32nd Edition): List Price: ￥1,348.50

￥1,280.61 Save ￥67.89 (5%)


China Master Tax Guide 2021 (14th Edition): List Price: ￥1,562.40

￥1,515.53 Save ￥46.87 (3%)


Hong Kong Company Law & Compliance Practical Toolkit (Basic Package): ￥4,214.76


Hong Kong Company Secretary's Practice Manual, 5th Edition: List Price: ￥1,283.40

￥1,244.90 Save ￥38.50 (3%)


Hong Kong Directors' Manual, 5th Edition: List Price: ￥1,283.40

￥1,244.90 Save ￥38.50 (3%)


Hong Kong Financial Reporting Standards for SMEs (2nd Edition): List Price: ￥1,395.00

￥1,353.15 Save ￥41.85 (3%)


Hong Kong Listed Companies: Law and Practice, 2nd Edition: List Price: ￥1,841.40

￥1,786.16 Save ￥55.24 (3%)


China Master GAAP Guide (12th Edition): List Price: ￥1,395.00

￥1,353.15 Save ￥41.85 (3%)


A Concise Guide to Corporate Compliance Management (2nd Edition): List Price: ￥632.40

￥613.43 Save ￥18.97 (3%)


Wiley IFRS 2023: Interpretation and Application of IFRS Standards: List Price: ￥1,162.50

￥1,127.63 Save ￥34.88 (3%)


Hong Kong Company Secretary Checklist, 2nd Edition: List Price: ￥1,283.40

￥1,244.90 Save ￥38.50 (3%)


Hong Kong GAAP: A Master Guide to Financial Reporting Standards 2023 (17th Edition): List Price: ￥1,395.00

￥1,353.15 Save ￥41.85 (3%)


Taxation in Hong Kong: A Practical Guide 2023-2024 (9th Edition): List Price: ￥1,283.40

￥1,244.90 Save ￥38.50 (3%)

“

Ordering from Professional Bookshop is fantastic, quick delivery great products, great customer service Siti L.
This is a great bookstore and have had no problems with them and all my orders have come on time and in good condition. Yang X.
Everything is perfect. Fast delivery. I highly recommend this website to all my friends and colleagues. Thanks Hoi Man L.
So thankful I am receiving all my books, thank you to all for a great service and excellent products Clinton K.
Professional Bookshop is amazing! I've been a loyal customer for over 5 years. Returns are easy to request, book or delivery complaints are taken seriously and the customer service team is friendly and patient. Mick D.
I wanted to informed you that the customer service is excellent. They were so polite and nice. I would continue to buy books from Professional Bookshop. Jingsong C.
Fast and quick service. Easy transaction method, arrived sooner than expected. Excellent packaging and the books received are in perfect condition! Thank you very much! I love the book and its quality. Saori B.
I can order any accounting books from worldwide from Professional Bookshop. Love this website and save my time to search from internet. Lingxiao R.
It is just so easy to find what you are always looking for and sometimes you can even find it up to 80% off what you would in the normal store. Graeme R.
I love shopping on Professional Bookshop! They have a wide range of accounting book with competent prices. Free shipping in Hong Kong is also really handy! Fergus Y.
Professional Bookshop is a great bookstore, I must say. Buying books in Professional Bookshop is so easy, great and reliable. It is highly recommendable. Deborah D.
A great site to shop accounting books and everything and with discountable prices. It’s my first choice whenever i want to shop something. Most trusted site. Zeng Z.
I found the books I needed and at a very low price. I am very happy and will definitely use it in the future Brian W.
I have been using Professional Bookshop for a while now. I am very impressed with customer service and delivery. When I need to have a return it is done very diligently. Olivia L.
Professional Bookshop is my default go to for finding the best prices and reading details of law books before buying. Detailed book description is very helpful. Tracy W.
I've been using Professional Bookshop since 2011 and they actually great, I always received great service and my book arrives on time. Lisa C.

所有书籍

Transfer Pricing and Financing

Free delivery Hong Kong?

详细

你可能需要

What Our Customers Say?

所有书籍

Transfer Pricing and Financing

Free delivery Hong Kong?

详细

你可能需要

What Our Customers Say?

video title