Suggested Approaches to Harmonization of Transfer Pricing and Customs Rules

Suggested Approaches to Harmonization of Transfer Pricing and Customs Rules PDF Author: S.K. Bilaney
Publisher:
ISBN:
Category :
Languages : en
Pages :

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Book Description
The author proposes ways in which transfer pricing and customs valuation rules could be harmonized so as to provide greater certainty for taxpayers.

Suggested Approaches to Harmonization of Transfer Pricing and Customs Rules

Suggested Approaches to Harmonization of Transfer Pricing and Customs Rules PDF Author: S.K. Bilaney
Publisher:
ISBN:
Category :
Languages : en
Pages :

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Book Description
The author proposes ways in which transfer pricing and customs valuation rules could be harmonized so as to provide greater certainty for taxpayers.

Customs Valuation and Transfer Pricing

Customs Valuation and Transfer Pricing PDF Author: Juan Martin Jovanovich
Publisher: Kluwer Law International B.V.
ISBN: 9041161422
Category : Law
Languages : en
Pages : 216

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Book Description
Issues of transfer pricing have come to the fore in both international tax and customs regimes. In particular, the problem of how to apply the two systems of valuation to the same transaction is of widespread concern. This well-known book, now in a fully updated second edition, is a problem-solving guide for professionals charged with valuating transactions in their client’s or company’s best interests. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, it offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized. Among other essential elements, the author discusses the following in depth: – the OECD Transfer Pricing Guidelines; – the GATT/WTO Customs Valuation Code (GVC) and other valuation rules in key jurisdictions and regional agreements; – the OECD and UN model tax conventions; – the arm’s length principle; – methods, both traditional and new, of determining whether the parties’ relationship in uenced the price; and – additions to and deductions from the customs value. This second edition discusses new developments in the eld, including a chapter on Commentary 23.1 and Case Study 14.1 of the Technical Committee on Customs Valuation of the World Customs Organization (WCO) – the rst international instruments linking transfer pricing and customs valuation. The book concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing year-end adjustments to transaction value would be consistent with Article 1 of the GVC. The book will continue to provide practitioners, customs administrations, and academics with a highly practical analysis of the intersection of transfer pricing and customs valuation. It will be welcomed by customs administrations charged with examining the acceptability of a transaction value xed between related parties and by multinational companies as a truly actionable tool they can use to optimize decision-making as it relates to transfer pricing and customs valuation in a “real world” setting.

Transfer Pricing and Customs Valuation

Transfer Pricing and Customs Valuation PDF Author: Anuschka Bakker
Publisher: IBFD
ISBN: 9087220596
Category : Customs appraisal
Languages : en
Pages : 695

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Book Description
This book discusses the intricate role of transfer pricing and customs value in international business environment. It examines the relationship between valuation for transfer pricing purposes and valuation for customs, and the significance of the relationship for multinational enterprises, tax authorities and customs administrations. The book begins by reviewing relevant international standards such as the OECD Guidelines and the GATT/WTO Customs Valuation Agreement. This is followed by a discussion of related issues such as VAT and administrative matters. Country chapters provide an overview of the applicable legislation and valuation methods, and case studies allow direct comparison between the practices of the different countries. The book concludes by summarizing the existing relationship between transfer pricing valuations and customs valuations, and by suggesting possible solutions towards a more integrated approach.

Customs Valuation and Transfer Pricing:Is It Possible to Harmonize Customs and Tax Rules?

Customs Valuation and Transfer Pricing:Is It Possible to Harmonize Customs and Tax Rules? PDF Author: Juan Jovanovich
Publisher: Springer
ISBN:
Category : Business & Economics
Languages : en
Pages : 168

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Book Description
Although valuation is fundamental to both tax and customs liability in international transactions, values calculated by the two regimes can differ, often markedly, in situations where no clear rules of transfer pricing apply. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, Customs Valuation and Transfer Pricing offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized.Among the essential elements of this important thesis, the author discusses the following in depth: the OECD Transfer Pricing Guidelines; the GATT/WTO Valuation Code (GVC); the arm's length principle; methods, both traditional and new, of determining whether the parties' relationship influenced the price; and additions to and deductions from the customs value. The study concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing compensatory adjustments to transaction value would be consistent with Article 1 of the GVC.

Customs Valuation and Transfer Pricing [microform] : is it Possible to Harmonize Customs and Tax Rules?

Customs Valuation and Transfer Pricing [microform] : is it Possible to Harmonize Customs and Tax Rules? PDF Author: Juan Martin Jovanovich
Publisher: National Library of Canada = Bibliothèque nationale du Canada
ISBN:
Category : Tariff
Languages : en
Pages : 294

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Book Description


Customs Valuation and Transfer Pricing : ICC Proposals

Customs Valuation and Transfer Pricing : ICC Proposals PDF Author: J-M. Salva
Publisher:
ISBN:
Category :
Languages : en
Pages :

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Book Description
The article studies the relationship between transfer pricing and customs valuation. The author explains two different approaches of transfer pricing, the first one adopted by tax agencies, based on the OECD Transfer Pricing Guidelines and the second adopted by customs agencies, based on the WTO Customs Valuation Agreement (CVA). From the business perspective, the divergence between the two taxation regimes is an obstacle to the liberalization of trade and inhibits international development for companies. On the other hand, the International Chamber of Commerce (ICC) believes that the WTO CVA and the use of the OECD Guidelines are enough to settle the issue of customs valuation and transfer pricing. However, ICC specifies that tax and customs approaches of intercompany transactions should converge to the same value. In this goal, ICC published a policy statement in 2012, which has been integrated in the WCO guidelines. This statement, based on the harmonization of the current rules, contains several additional options to derive customs value. The author states that the Union Customs Code does not contain any evolution from a transfer pricing perspective but contains some negatives changes regarding custom valuation. Also, the opportunity of the WCO Free Trade Agreement should be taken to move forward on this issue.

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.

Transfer Pricing in SMEs

Transfer Pricing in SMEs PDF Author: Veronika Solilova
Publisher: Springer
ISBN: 3319690655
Category : Business & Economics
Languages : en
Pages : 205

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Book Description
This book provides a detailed assessment of current approaches to transfer pricing in the context of small- and middle-sized enterprises (SMEs), including the newest update of Transfer Pricing Guidelines from 10 July 2017. It analyzes the transfer pricing rules for SMEs across the European Union (EU) and explores two alternative approaches as suitable solutions for current transfer pricing issues. The authors evaluate and discuss alternative approaches like Safe Harbour and Common Consolidated Corporate Tax Base (CCCTB). Taking into account the prominent role of SMEs in the European Union’s economy, the book also puts forward policy recommendations to achieve the long-term goals of the EU’s 2020 agenda.

The Economics of Transfer Pricing

The Economics of Transfer Pricing PDF Author: Lorraine Eden
Publisher:
ISBN: 9781840648324
Category : Transfer pricing
Languages : en
Pages : 0

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Book Description
This authoritative single-volume collection offers the most influential papers relating to the economics of transfer pricing. The literature notably covers the topic in light of divisionalization, government regulations, bargaining models, market distortions and product characteristics as well as touching on the important subjects of empirical estimates of transfer price manipulation and transfer mispricing estimates. Accompanied by an original introduction by Lorraine Eden, one of the founders and a leading contributor to the field, this volume promises to be useful reading for doctoral students, faculty members and policy makers who wish to extend their knowledge on the economics of transfer pricing.

Customs Law of the European Union

Customs Law of the European Union PDF Author: Massimo Fabio
Publisher: Kluwer Law International B.V.
ISBN: 9041161317
Category : Law
Languages : en
Pages : 660

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Book Description
Today, global competition obliges companies dealing in international trade to modernize their procedures of delivery in order to minimize the customs burden and simplify the relation with customs authorities. Customs planning is the current option to be effective in the worldwide marketplace. However, customs officials are facing new challenges: they must ensure the smooth flow of trade while applying necessary controls on the one hand, while protecting the health and safety of the Community's citizens on the other. To achieve and maintain the correct balance between these demands, control methods are constantly evolving raising major challenges to those charged with planning and compliance. This book is a highly practical work dealing with the ins and outs of European Union (EU) customs law. Cases of study, jurisprudence and comparative law support the analysis of the different legal tools. The consolidated principles ruling the transactions within WTO Member States applied in EU law offer the readers the opportunity to understand how customs rules can be applied in any customs jurisdiction. Authored by an international tax lawyer with extensive experience enforcing EU customs law as a former member of Italy’s financial police, this handy resource is designed to help the reader stay in compliance with the laws controlling EU importing and exporting while structuring transactions in a business-friendly manner. “This book is a reference work in the customs law field. It deals thoroughly and practically with all the matters that a customs law practitioner would need to know. This book works well both for beginners and experts, since both will find needed information and insight in it.” EU Law Live – Book Review by Darya Budova, Senior Associate, Uría Menéndez