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Author: John Smullen
Publisher: Woodhead Publishing
ISBN: 9781855733725
Category : Business & Economics
Languages : en
Pages : 168
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Book Description
A cutting-edge study of transfer pricing in the increasingly competitive financial services sector. It examines the many issues involved and suggests different techniques for establishing efficient transfer pricing systems. This book is essential reading for all organisations that raise and loan funds in today's global markets.
Author: John Smullen
Publisher: Woodhead Publishing
ISBN: 9781855733725
Category : Business & Economics
Languages : en
Pages : 168
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Book Description
A cutting-edge study of transfer pricing in the increasingly competitive financial services sector. It examines the many issues involved and suggests different techniques for establishing efficient transfer pricing systems. This book is essential reading for all organisations that raise and loan funds in today's global markets.
Author: Anuschka Bakker
Publisher: IBFD
ISBN: 9087221525
Category : Business & Economics
Languages : en
Pages : 593
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Book Description
This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
Author: Malik Hill
Publisher:
ISBN:
Category :
Languages : en
Pages : 134
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Book Description
In this monograph M. Hill will focus on how treasury transformation can support your transfer pricing compliance and streamline your inter-company finance processes, more specifically the pricing of indo-company loans financial guarantees and the determination of internal cashflow and in our bank interest rates First the author shall start by giving you some more background on transfer pricing and why it is important for corporate treasurers secondly the author will focus on the arm's length pricing of inter-company loans and financial guarantees stand alone financial transactions within the group, thirdly the author will switch towards four types of transaction, the determination of internal in-house bank interest rates and cash flow rates as there is much more complexity in this process compared to into company loans and then lastly the author will give you the key takeaways and also suggests designers approach based on client cases.
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.
Author: John Abrahamson
Publisher: Kluwer Law International B.V.
ISBN: 9403510951
Category : Law
Languages : en
Pages : 448
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Book Description
Banking is an increasingly global business, with a complex network of international transactions within multinational groups and with international customers. This book provides a thorough, practical analysis of international taxation issues as they affect the banking industry. Thoroughly explaining banking’s significant benefits and risks and its taxable activities, the book’s broad scope examines such issues as the following: taxation of dividends and branch profits derived from other countries; transfer pricing and branch profit attribution; taxation of global trading activities; tax risk management; provision of services and intangible property within multinational groups; taxation treatment of research and development expenses; availability of tax incentives such as patent box tax regimes; swaps and other derivatives; loan provisions and debt restructuring; financial technology (FinTech); group treasury, interest flows, and thin capitalisation; tax havens and controlled foreign companies; and taxation policy developments and trends. Case studies show how international tax analysis can be applied to specific examples. The Organisation for Economic Co-operation and Development Base Erosion and Profit Shifting (OECD BEPS) measures and how they apply to banking taxation are discussed. The related provisions of the OECD Model Tax Convention are analysed in detail. The banking industry is characterised by rapid change, including increased diversification with new banking products and services, and the increasing significance of activities such as shadow banking outside current regulatory regimes. For all these reasons and more, this book will prove to be an invaluable springboard for problem solving and mastering international taxation issues arising from banking. The book will be welcomed by corporate counsel, banking law practitioners, and all professionals, officials, and academics concerned with finance and its tax ramifications.
Author: Robert T. Cole
Publisher: Aspen Publishers
ISBN:
Category : Business & Economics
Languages : en
Pages : 1302
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Book Description
Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.
Author: BNA International Inc
Publisher:
ISBN: 9780906524916
Category : Financial institutions
Languages : en
Pages : 60
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Book Description
Author: Dirk A. Zetzsche
Publisher: Kluwer Law International B.V.
ISBN: 9041149953
Category : Law
Languages : en
Pages : 948
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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.
Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709411971
Category : Law
Languages : en
Pages : 176
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Book Description
Transfer pricing and financial transactions: Issues and developments Since years, issues related to transfer pricing and intra-group financing are prominent in the agendas of both taxpayers and governments. The extreme relevance of these topics and the need to address them has attracted the interest of various international organizations for a long time. Already in 1972, the OECD emphasized that these topics required further attention, and the 1979 OECD Transfer Pricing Report dedicated an entire chapter to issues concerning loans. However, the first OECD Transfer Pricing Guidelines issued in 1995 did not include a chapter on these issues. Twenty-five years later, in February 2020, the OECD finally released its 2022 Transfer Pricing Guidelines on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines. Meanwhile, in 2021, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries. With those welcomed recent developments from the OECD and the UN, the topic is now being extensively discussed, especially considering the necessary implementation of the guidance at the national level and the future answers from the tax courts at national and European levels when dealing with this matter. This publication discusses the most important issues and recent developments related to this topic. Beginning with an in-depth analysis on the accurate delineation of financial transactions, it further deals with the specific transactions concerning loans, financial guarantees, and cash pooling. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium held in October 2021 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.
Author: Morgan Bright Gordon
Publisher:
ISBN:
Category :
Languages : en
Pages : 5
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Book Description
Recent upheavals in the global financial sector have exacerbated the situation in terms of stringent regulatory compliances and restrictions. Capital requirements are increasing and achieving revenue growth continues to be a challenge amidst weak macro-economic conditions. These forces have led to eroding margins for financial institutions and are severely testing their ability to achieve sustainable profitability. The situation actually warrants financial institutions to review their conventional methodology of measuring and reporting business performance. This article takes a closer look at FTP and how it can add value to the banking organization for better performance management at the granular level.
