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Author: Karol Dziwinski
Publisher: Kluwer Law International B.V.
ISBN: 9403540508
Category : Law
Languages : en
Pages : 243
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Book Description
Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle – known as DEMPE (development, enhancement, maintenance, protection and exploitation) – describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following: role of the DEMPE concept within the framework of international tax law and transfer pricing; interplay of the DEMPE concept with the arm’s length principle; full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences; modes of application of the DEMPE concept which can be directly implemented in practice; and additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept. The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations. Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises – and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept – tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.
Author: Karol Dziwinski
Publisher: Kluwer Law International B.V.
ISBN: 9403540508
Category : Law
Languages : en
Pages : 243
Get Book Here
Book Description
Under the widely applied rules of the OECD Transfer Pricing Guidelines, allocation of the returns from the exploitation of intellectual property should be shared among all entities that contribute towards the profit-generating value of an intangible. This important book, in its detailed treatment of compliance with this principle – known as DEMPE (development, enhancement, maintenance, protection and exploitation) – describes exactly how both taxpayers and tax authorities can achieve an accurate assessment of transactions in order to arrive at an appropriate transfer pricing outcome. Analysing the legal, economic, and business management aspects of multinational enterprises activities, the book provides a comprehensive understanding of the DEMPE concept both in theory and in practice. Fully covered are such issues and topics as the following: role of the DEMPE concept within the framework of international tax law and transfer pricing; interplay of the DEMPE concept with the arm’s length principle; full description of each DEMPE function and analysis in the light of possible tax and transfer pricing consequences; modes of application of the DEMPE concept which can be directly implemented in practice; and additional tools (e.g., value chain analysis or RACI matrix) useful in applying the DEMPE concept. The book also provides the first in-depth analysis of the interplay between the DEMPE concept and the licence model in its various structural variations. Taking into account that intangibles amount to 84% of the market value of the S&P 500 companies and that over 80% of global trade transactions can be linked to value chains of multinational enterprises – and recognizing the scarcity of guidance heretofore on the application of the DEMPE concept – tax advisors, corporate counsels, tax authorities, and academics around the world are sure to appreciate and benefit greatly from this matchless and practical book.
Author: Shu-Chien Chen
Publisher: Kluwer Law International B.V.
ISBN: 9403532963
Category : Law
Languages : en
Pages : 471
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Book Description
International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. The author, through an intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more: theorising public benefits to be represented by taxation; reorganising different economic theories about tax neutrality and tax justice; advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach; designing the logical formulary apportionment system for digital economy; ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations; reducing the tax system’s complexity and the administrative burden it imposes on firms; eliminating transfer pricing complexity for intra-firm transactions; achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula; application of ‘destination-based’ rule for attributing the sales factor; and replacing the traditional permanent establishment nexus with a ‘factor presence nexus’. The presentation incorporates extensive comparison between the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.
Author: Breanne Robertson
Publisher:
ISBN: 9781732003071
Category : Flags
Languages : en
Pages : 371
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Book Description
"Investigating Iwo encourages us to explore the connection between American visual culture and World War II, particularly how the image inspired Marines, servicemembers, and civilians to carry on with the war and to remember those who made the ultimate sacrifice to ensure victory over the Axis Powers. Chapters shed light on the processes through which history becomes memory and gains meaning over time. The contributors ask only that we be willing to take a closer look, to remain open to new perspectives that can deepen our understanding of familiar topics related to the flag raising, including Rosenthal's famous picture, that continue to mean so much to us today"--
Author: Max Brooks
Publisher: Broadway Books
ISBN: 0770437400
Category : Fiction
Languages : en
Pages : 434
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Book Description
An account of the decade-long conflict between humankind and hordes of the predatory undead is told from the perspective of dozens of survivors who describe in their own words the epic human battle for survival, in a novel that is the basis for the June 2013 film starring Brad Pitt. Reissue. Movie Tie-In.
Author: Combat Studies Institute Press
Publisher: Military Bookshop
ISBN: 9781782663959
Category : History
Languages : en
Pages : 398
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Book Description
This work is a collection of observations, insights, and advice from over 50 serving and retired Senior Non-Commissioned Officers. These experienced Army leaders have provided for the reader, outstanding mentorship on leadership skills, tasks, and responsibilities relevant to our Army today. There is much wisdom and advice "from one leader to another" in the following pages.
Author: Maurer Maurer
Publisher:
ISBN:
Category : Aeronautics, Military
Languages : en
Pages : 706
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Book Description
Author: Shannon Caudill
Publisher: Military Bookshop
ISBN: 9781782666851
Category : History
Languages : en
Pages : 444
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Book Description
This anthology discusses the converging operational issues of air base defense and counterinsurgency. It explores the diverse challenges associated with defending air assets and joint personnel in a counterinsurgency environment. The authors are primarily Air Force officers from security forces, intelligence, and the office of special investigations, but works are included from a US Air Force pilot and a Canadian air force officer. The authors examine lessons from Vietnam, Iraq, Afghanistan, and other conflicts as they relate to securing air bases and sustaining air operations in a high-threat counterinsurgency environment. The essays review the capabilities, doctrine, tactics, and training needed in base defense operations and recommend ways in which to build a strong, synchronized ground defense partnership with joint and combined forces. The authors offer recommendations on the development of combat leaders with the depth of knowledge, tactical and operational skill sets, and counterinsurgency mind set necessary to be effective in the modern asymmetric battlefield.
Author: Darra Goldstein
Publisher: Ten Speed Press
ISBN: 0399580409
Category : Cooking
Languages : en
Pages : 322
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Book Description
100 traditional yet surprisingly modern recipes from the far northern corners of Russia, featuring ingredients and dishes that young Russians are rediscovering as part of their heritage. IACP AWARD FINALIST • LONGLISTED FOR THE ART OF EATING PRIZE • NAMED ONE OF THE BEST COOKBOOKS OF THE YEAR BY THE WASHINGTON POST AND FORBES “A necessary resource for food writers and for eaters, a fascinating read and good excuse to make fermented oatmeal.”—Bon Appétit Russian cookbooks tend to focus on the food that was imported from France in the nineteenth century or the impoverished food of the Soviet era. Beyond the North Wind explores the true heart of Russian food, a cuisine that celebrates whole grains, preserved and fermented foods, and straightforward but robust flavors. Recipes for a dazzling array of pickles and preserves, infused vodkas, homemade dairy products such as farmers cheese and cultured butter, puff pastry hand pies stuffed with mushrooms and fish, and seasonal vegetable soups showcase Russian foods that are organic and honest--many of them old dishes that feel new again in their elegant minimalism. Despite the country's harsh climate, this surprisingly sophisticated cuisine has an incredible depth of flavor to offer in dishes like Braised Cod with Horseradish, Roast Lamb with Kasha, Black Currant Cheesecake, and so many more. This home-style cookbook with a strong sense of place and evocative storytelling brings to life a rarely seen portrait of Russia, its people, and its palate—with 100 recipes, gorgeous photography, and essays on the little-known culinary history of this fascinating and wild part of the world.
Author: J. Melissen
Publisher: Springer
ISBN: 0230554938
Category : Political Science
Languages : en
Pages : 242
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Book Description
After 9/11, which triggered a global debate on public diplomacy, 'PD' has become an issue in most countries. This book joins the debate. Experts from different countries and from a variety of fields analyze the theory and practice of public diplomacy. They also evaluate how public diplomacy can be successfully used to support foreign policy.
Author: Simon Sinek
Publisher: Penguin
ISBN: 0735213526
Category : Business & Economics
Languages : en
Pages : 272
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Book Description
From the New York Times bestselling author of Start With Why and Leaders Eat Last, a bold framework for leadership in today’s ever-changing world. How do we win a game that has no end? Finite games, like football or chess, have known players, fixed rules and a clear endpoint. The winners and losers are easily identified. Infinite games, games with no finish line, like business or politics, or life itself, have players who come and go. The rules of an infinite game are changeable while infinite games have no defined endpoint. There are no winners or losers—only ahead and behind. The question is, how do we play to succeed in the game we’re in? In this revelatory new book, Simon Sinek offers a framework for leading with an infinite mindset. On one hand, none of us can resist the fleeting thrills of a promotion earned or a tournament won, yet these rewards fade quickly. In pursuit of a Just Cause, we will commit to a vision of a future world so appealing that we will build it week after week, month after month, year after year. Although we do not know the exact form this world will take, working toward it gives our work and our life meaning. Leaders who embrace an infinite mindset build stronger, more innovative, more inspiring organizations. Ultimately, they are the ones who lead us into the future.
