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Author: Raffaele Petruzzi
Publisher: Linde Verlag GmbH
ISBN: 370941038X
Category : Law
Languages : en
Pages : 472
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Book Description
Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Author: Raffaele Petruzzi
Publisher: Linde Verlag GmbH
ISBN: 370941038X
Category : Law
Languages : en
Pages : 472
Get Book
Book Description
Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Author:
Publisher:
ISBN: 9789087226879
Category :
Languages : en
Pages :
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Book Description
Author: Werner C. Haslehner
Publisher:
ISBN: 9789087226893
Category : Commercial law
Languages : en
Pages :
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Book Description
This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework
Author: OECD
Publisher: Org. for Economic Cooperation & Development
ISBN: 9789264241237
Category :
Languages : en
Pages : 186
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Book Description
The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
Author: Juergen H. Daum
Publisher: John Wiley & Sons
ISBN: 0470859237
Category : Business & Economics
Languages : de
Pages : 444
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Book Description
With the use of practical in-depth case studies and interviews with leading experts in the field, this book analyses the key elements in value creation in the new age. It provides practical guidance to organisations that will allow them to migrate successfully into an economy that demands new business models.
Author: Werner Haslehner
Publisher: Kluwer Law International B.V.
ISBN: 9403503351
Category : Law
Languages : en
Pages : 370
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Book Description
The increasingly digitalized global economy is undermining the usefulness of many traditional tax concepts. In addition to issues of double taxation and double non-taxation, important questions arise concerning the allocation of taxing rights in respect of income from cross-border digital transactions. This is the first book to analyse what changes are possible, necessary and feasible in order to forestall the unravelling of the existing international tax framework. Focusing in turn on the legal framework, specific proposals for adapting tax concepts for the digital economy, types of transactions and administrative issues such as those around data protection and digital currencies, the expert contributors discuss such challenges to taxation as the following: the pervasiveness of intangible assets; new value creation models; the ascendance of the sharing economy and digital services; virtual currencies; the importance of user participation for digital platforms; cloud computing; the impact of Big Data on tax enforcement; virtual business presence; and the influence of robotization. Throughout, the authors describe and analyse proposals made by the Organisation for Economic Co-operation and Development (OECD), the European Union (EU) and individual countries and their likely impact going forward. They also attend to the limits imposed on reform possibilities by public international law, EU law and constitutional law. It is generally acknowledged that there is a need to monitor how the digital transformation may be impacting value creation. This book is a key milestone toward developing a durable, long-term solution to the tax challenges posed by the digitalization of the economy. With its thorough scrutiny of proposals for digital services tax and virtual permanent establishments, insightful analysis of digital services and detailed description of the impact of big data on tax administration and taxpayer protection, it will quickly prove indispensable for tax practitioners and the international tax community more generally.
Author: Svetla Marinova
Publisher: Springer
ISBN: 3319308033
Category : Business & Economics
Languages : en
Pages : 425
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Book Description
This edited collection brings into focus the meanings, interpretations and the process of value creation in international business. Exploring value creation in the context of emerging and developed economies, Volume 1 takes the perspective of multinational firms and examines various modes of foreign market servicing varying from exporting to joint venture, mergers and acquisition and strategic alliances. Providing theoretical and practical insights, the authors open an intellectual debate into what value is, and how it is created through the internationalization activities of firms. Value Creation in International Business is a pioneering two volume work intended to provoke theoretical and empirical development in International Business research. Moreover, it is intended as a bridge between concepts derived from general business firm-level research agendas such as value creation and business model, and internationalization approaches and activities of firms.
Author: Raffaele Petruzzi
Publisher:
ISBN: 9783707341232
Category :
Languages : en
Pages : 556
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Book Description
Author: Daniela Venanzi
Publisher: Springer Science & Business Media
ISBN: 884702451X
Category : Business & Economics
Languages : en
Pages : 81
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Book Description
The choice of financial performance measures is one of the most critical challenges facing organizations. The accounting-based measures of financial performance have been viewed as inadequate, as firms began focusing on shareholder value as the primary long-term objective of the organization. Hence, value-based metrics were devised that explicitly incorporate the cost of capital into performance calculations. Despite the increasing emphasis on these value-based measures, no definitive evidence exists of which metric works better than others, and on the extent to which any of them is superior to traditional accounting measures. In this scenario, the objective of this book is contributing to the ongoing dialogue on the appropriateness of different financial performance measures, by providing a systematic and updated review of the major value-based measures, by highlighting their respective strengths and weaknesses and by comparing the main international empirical evidence on their effectiveness. This book can be a powerful tool for guiding managers and graduate students in the “tangled forest” of the existing metrics, by providing them with the quick, but adequate knowledge for consistently adopting them.
Author: Bartley J. Madden
Publisher: John Wiley & Sons
ISBN: 1119706629
Category : Business & Economics
Languages : en
Pages : 272
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Book Description
PRAISE FOR VALUE CREATION PRINCIPLES "In Value Creation Principles, Madden introduces the Pragmatic Theory of the Firm that positions the firm as a system fueled by human capital, innovation, and, at a deeper level, imagination. He challenges us to understand how we know what we think we know in order to better discover faulty assumptions that often are camouflaged by language. His knowledge building loop offers guideposts to design experiments and organize feedback to facilitate early adaptation to a changed environment and to avoid being mired in ways of thinking rooted in 'knowledge' of what worked well in the past—a context far different from the context of today. His book explains a way of being that enables those who work for, or invest in, business firms to see beyond accounting silos and short-term quarterly earnings and to focus on capabilities instrumental for creating long-term future and sustainable value for the firm's stakeholders. I can't recommend this astounding book enough especially given its deep and timely insights for our world today." —John Seely Brown, former Chief Scientist for Xerox Corp and Director of its Palo Alto Research Center (PARC); co-author with Ann Pendleton-Jullian of Design Unbound: Designing for Emergence in a White Water World "In contrast to existing abstract theories of the firm, Madden's pragmatic theory of the firm connects management's decisions in a practical way to a firm's life cycle and market valuation. The book promotes a firm's knowledge building proficiency, relative to competitors, as the fundamental driver of a firm's long-term performance, which leads to insights about organizational capabilities, intangible assets, and excess shareholder returns. Value Creation Principles is ideally suited to facilitate progress in the New Economy by opening up the process by which firms build knowledge and create value, which is a needed step in revising how neoclassical economics treats the firm." —Tyler Cowen, Professor of Economics, George Mason University; co-author of the popular economics blog Marginal Revolution "Bartley Madden rightfully points out that both textbook and more advanced economic theories of the firm fail to address the concerns of top management and boards of directors. He offers a tantalizing pragmatic alternative that directly connects to quantitative changes in the firm's market value. His framework gives recognition to the importance of intangible assets, and his pragmatic approach is quite complementary to the Dynamic Capabilities framework that strategic managers implicitly and sometimes explicitly employ." —David J. Teece, Thomas W. Tusher Professor in Global Business, Faculty Director, Tusher Center for the Management of Intellectual Capital, Haas School of Business, University of California, Berkeley
