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Author: Kuldeep Sharma
Publisher: Kluwer Law International B.V.
ISBN: 9403535520
Category : Law
Languages : en
Pages : 252
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Book Description
Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.
Author: Kuldeep Sharma
Publisher: Kluwer Law International B.V.
ISBN: 9403535520
Category : Law
Languages : en
Pages : 252
Get Book Here
Book Description
Advance pricing agreements or arrangements (APAs) are designed as a dispute prevention mechanism for transfer pricing related issues and provide certainty to taxpayers on taxation of cross-border transactions. Since the APA procedure was introduced by tax authorities in the late 1980s, it has gradually taken hold worldwide and evolved along several dimensions with important characteristics. This book, the first exclusively dedicated to the global APA regime, provides a comprehensive, in-depth discussion of the APA concepts and procedures in twenty-five jurisdictions across Europe, Asia, Asia Pacific, North America, South America and Africa, noting the particular genesis, features, and progress made under each programme. The analysis covers such elements as the following: the types of APAs and their characteristics; the main steps involved in an APA process; key advantages of APA programme and comparative study of the APA as a preferred dispute prevention mechanism over other dispute resolution mechanisms; key issues observed and in practice by various APA authorities worldwide inter alia involving, cost base of captive entities, resolution of transfer pricing issues involving intangibles, location savings, joint site visits, attribution of profits to PEs, APAs for small businesses, abbreviated procedure for renewal of APAs, significance of economic nexus prior to the grant of APAs and other relevant issues; exchange of APA rulings equip tax authorities to quickly identify risk areas so as to curb Base Erosion and Profits Shifting (BEPS), which augurs well for the APA programme and is another milestone in its evolution process; APAs provide jurisdictions with an excellent platform to fostering a non-adversarial tax regime. The author includes an extended case study of India’s APA programme, highlighting some of its conspicuous elements with equal focus on certain special characteristics of APAs in Australia, Canada, France, Germany, Ireland, Korea, The Netherlands, Poland, UK and the United States. Factors influencing speedier processing and suggestions on further improvement of APA programmes are also included. Numerous tables and figures illustrate all aspects associated with APAs. With more economies opening up and the worldwide implementation of the OECD/G20 BEPS Action Reports in an endeavour to combat BEPS, access and recourse to APAs is sure to grow. This invaluable book will enable tax administrations to learn from each other’s experiences and help to prevent costly and time-consuming transfer pricing audits and litigation for multinational enterprises. The book will be welcomed by revenue officials, professionals, and advisors concerned with international taxation, as well as by tax law academics.
Author:
Publisher:
ISBN:
Category : Confidential communications
Languages : en
Pages : 408
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Book Description
Author: OECD
Publisher: OECD Publishing
ISBN: 9264772987
Category :
Languages : en
Pages : 96
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Book Description
This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by the People's Republic of China.
![Disability in American Life [2 volumes] PDF](https://books.google.com/books/content/images/frontcover/BRnOEAAAQBAJ?fife=w80-h100)
Author: Tamar Heller
Publisher: Bloomsbury Publishing USA
ISBN:
Category : Health & Fitness
Languages : en
Pages : 1104
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Book Description
Disability—as with other marginalized topics in social policy—is at risk for exclusion from social debate. This multivolume reference work provides an overview of challenges and opportunities for people with disabilities and their families at all stages of life. Once primarily thought of as a medical issue, disability is now more widely recognized as a critical issue of identity, personhood, and social justice. By discussing challenges confronting people with disabilities and their families and by collecting numerous accounts of disability experiences, this volume firmly situates disability within broader social movements, policy, and areas of marginalization, providing a critical examination into the lived experiences of people with disabilities and how disability can affect identity. A foundational introduction to disability for a wide audience—from those intimately connected with a person with a disability to those interested in the science behind disability—this collection covers all aspects of disability critical to understanding disability in the United States. Topics covered include characteristics of disability; disability concepts, models, and theories; important historical developments and milestones for people with disabilities; prominent individuals, organizations, and agencies; notable policies and services; and intersections of disability policy with other policy.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264790845
Category :
Languages : en
Pages : 76
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Book Description
This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by Lithuania.
Author: United States. Congress. House. Committee on Ways and Means
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 224
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Book Description
Author: Joel Cooper
Publisher: World Bank Publications
ISBN: 1464809704
Category : Business & Economics
Languages : en
Pages : 275
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Book Description
Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.
Author: Qiang Wei
Publisher: Frontiers Media SA
ISBN: 2889740943
Category : Medical
Languages : en
Pages : 145
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Book Description
Author: United States. Internal Revenue Service
Publisher:
ISBN:
Category : Tax administration and procedure
Languages : en
Pages : 642
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Book Description
Author: Shlomo Melmed
Publisher: Elsevier Health Sciences
ISBN: 0323933475
Category : Medical
Languages : en
Pages : 2379
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Book Description
Now fully revised and updated, Williams Textbook of Endocrinology, 15th Edition, remains your go-to reference for authoritative content on the full spectrum of adult and pediatric endocrine system disorders. World-renowned authors and editors expertly bridge the gap between basic science and clinical information, keeping you up to date with recent advances in medications, therapies, clinical trials, and more. This essential reference is a must-have resource for endocrinologists, endocrine surgeons, gynecologists, internists, pediatricians, and other clinicians who need current, comprehensive coverage of this multifaceted field. - Presents current information in a highly illustrated, user-friendly format for quick reference. - Includes new chapters on Skeletal Regulation of Metabolism, Digitized Approaches to Diabetes Therapeutics, and MODY and Atypical Diabetes. - Reflects updated approaches to transgender medicine as well as new coverage of viral infections, including COVID-19. - Covers hot topics such as personalized medicine; the latest methodologies and trends regarding cancer genomics, precision oncology, and cell biology; and updates in key areas such as adrenal dysfunction and diabetes. - Provides state-of-the-art coverage of diabetes, metabolic syndrome, metabolic bone disorders, obesity and thyroid disease, as well as pituitary, gonadal, and adrenal disorders, and much more—all designed to help you provide optimal care to every patient. - Features contributions from today's thought leaders in endocrinology. - Contains a selected reading list and highlighted key references nominated by the editors.
