Addressing Base Erosion and Profit Shifting

Addressing Base Erosion and Profit Shifting PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264192743
Category :
Languages : en
Pages : 91

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Book Description
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

Addressing Base Erosion and Profit Shifting

Addressing Base Erosion and Profit Shifting PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264192743
Category :
Languages : en
Pages : 91

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Book Description
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

Introduction to Transfer Pricing

Introduction to Transfer Pricing PDF Author: Jerome Monsenego
Publisher:
ISBN: 9789144092706
Category : Business & Economics
Languages : en
Pages : 163

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Book Description
Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.

United Nations Practical Manual on Transfer Pricing for Developing Countries 2017

United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 PDF Author: United Nations
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 672

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Book Description
The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.

Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition

Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264267999
Category :
Languages : en
Pages : 326

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Book Description
This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.

Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report

Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report PDF Author: OCDE,
Publisher: OCDE
ISBN: 9789264241466
Category : International business enterprises
Languages : en
Pages : 70

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Book Description
This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports

The Alternative Investment Fund Managers Directive

The Alternative Investment Fund Managers Directive PDF Author: Dirk A. Zetzsche
Publisher: Kluwer Law International B.V.
ISBN: 9041149953
Category : Law
Languages : en
Pages : 907

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Book Description
Apart from MiFID, the Alternative Investment Fund Managers Directive (AIFMD) may be the most important European asset management regulation of the early twenty-first century. In this in-depth analytical and critical discussion of the content and system of the directive, thirty-eight contributing authors – academics, lawyers, consultants, fund supervisors, and fund industry experts – examine the AIFMD from every angle. They cover structure, regulatory history, scope, appointment and authorization of the manager, the requirements for depositaries and prime brokers, rules on delegation, reporting requirements, transitional provisions, and the objectives stipulated in the recitals and other official documents. The challenging implications and contexts they examine include the following: – connection with systemic risk and the financial crisis; - nexus with insurance for negligent conduct; - connection with corporate governance doctrine; - risk management; - transparency; - the cross-border dimension; - liability for lost assets; - impact on alternative investment strategies, and - the nexus with the European Regulation on Long-Term Investment Funds (ELTIFR). Nine country reports, representing most of Europe’s financial centres and fund markets add a national perspective to the discussion of the European regulation. These chapters deal with the potential interactions among the AIFMD and the relevant laws and regulations of Austria, France, Germany, Italy, Luxembourg, Liechtenstein, The Netherlands, Malta and the United Kingdom. The second edition of the book continues to deliver not only the much-needed discussion of the inconsistencies and difficulties when applying the directive, but also provides guidance and potential solutions to the problems it raises. The second edition considers all new developments in the field of alternative investment funds, their managers, depositaries, and prime brokers, including, but not limited to, statements by the European Securities and Markets Authority (ESMA) and national competent authorities on the interpretation of the AIFMD, as well as new European regulation, in particular the PRIIPS Regulation, the ELTIF Regulation, the Regulation on European Venture Capital Funds (EuVeCaR), the Regulation on European Social Entrepreneurship Funds (EUSEFR), MiFID II, and UCITS V. The book will be warmly welcomed by investors and their counsel, fund managers, depositaries, asset managers, administrators, as well as regulators and academics in the field.

Action Plan on Base Erosion and Profit Shifting

Action Plan on Base Erosion and Profit Shifting PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264202714
Category :
Languages : en
Pages : 44

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Book Description
This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264265120
Category :
Languages : en
Pages : 612

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Book Description
This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations PDF Author: Organisation for Economic Co-operation and Development
Publisher: Organisation for Economic Co-operation and Development
ISBN:
Category : Business & Economics
Languages : en
Pages : 76

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Book Description
Includes 1999 update. 1998 update in back.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264278796
Category :
Languages : en
Pages : 104

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Book Description
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).