OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 PDF Download
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Author: OECD
Publisher: OECD Publishing
ISBN: 9264921915
Category :
Languages : en
Pages : 658
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Book Description
In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264921915
Category :
Languages : en
Pages : 658
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Book Description
In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.
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: Lorraine Eden
Publisher: University of Toronto Press
ISBN: 9780802007766
Category : Business & Economics
Languages : en
Pages : 788
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Book Description
Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264167773
Category :
Languages : en
Pages : 107
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Book Description
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.
Author: Alan M. Rugman
Publisher: Routledge
ISBN: 1351999680
Category : Business & Economics
Languages : en
Pages : 292
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Book Description
One of the reasons for the success of multinational enterprises in their ability to create in their supranational organisations "internal markets" which eliminate the imperfections of external world markets caused by tariffs on trade, restrictions on the flow of capital, information costs and so on. The method multinationals use to create and sustain internal markets is transfer pricing. Multinationals use to their advantage the difference between nominal accounting and real transfers from their head offices to a subsidiary in different countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals’ use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.
Author: Business International Corporation
Publisher:
ISBN:
Category : Foreign exchange
Languages : en
Pages : 212
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Book Description
A comprehensive guide to corporate practices in internal control and tax compliance. Included are case studies of how firms in a variety of industries approach transfer pricing.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264075348
Category :
Languages : en
Pages : 247
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Book Description
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.
Author: Wolfgang Schön
Publisher: Springer Science & Business Media
ISBN: 3642259804
Category : Law
Languages : en
Pages : 308
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Book Description
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Author: James R. Hines
Publisher: University of Chicago Press
ISBN: 0226341755
Category : Business & Economics
Languages : en
Pages : 285
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Book Description
Because the actions of multinational corporations have a clear and direct effect on the flow of capital throughout the world, how and why these firms behave the way they do is a major issue for national governments and their policymakers. With an unprecedented ability to adjust the scale, character, and location of their global operations, international corporations have become increasingly sensitive to the kind and degree of tax obligations imposed on them by both host and home countries. Tax rules affect the volume of foreign direct investment, corporate borrowing, transfer pricing, dividend and royalty payments, and research and development. National governments that tax the profits of international firms face important challenges in designing tax policies to attract them. This collection examines the global ramifications of tax policies, offering up-to-date, theoretically innovative, and empirically sound perspectives on a problem of immense significance to future economic growth around the globe.
Author: Wagdy M. Abdallah
Publisher: Praeger
ISBN:
Category : Business & Economics
Languages : en
Pages : 184
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Book Description
"In this valuable work Professor Abdallah lays out the factors a good international transfer pricing system should have. . . . A multinational enterprise must reach a number of business decisions involving transfer pricing, such as where to manufacture a specific product, levels of capital investment, and profit planning by location. Rather than shooting from the hip' and trying to solve problems one at a time, Professor Abdallah says, companies should develop a comprehensive policy to resolve the inevitable problems. In short, transfer pricing problems are here and will continue to be here. While there is no single answer, a written policy approach is best. Anyone responsible for international transfer pricing will be helped immeasurably by referring to this valuable book." Management Accounting
