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Author: Rahul K Mitra
Publisher: Wolters Kluwer India Pvt. Limited
ISBN: 9389859743
Category : Fiction
Languages : en
Pages : 111
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Book Description
Are some of the theories of OECD and UN around marketing intangibles sacrosanct? The same have been countered through qualitative and quantitative arguments. Quantitative arguments are based upon real life scenarios, with reference to statistical analyses on selected empirical data. Genesis of litigation around marketing intangibles analysed, along with solutions. Concept of royalties for licensed manufacturers explained in the context of regulatory regime of India. Practical solutions provided on harmonisation of transfer pricing and customs duty regulations in complex cases. Concept of attribution of profits to dependent agency permanent establishments explained, with reference to Berry Ratio. Foreword by Dr. Raffalle Dr. Raffaele Petruzzi & Dr. Alfred Storck Professors of Vienna University of Economics and Business
Author: Rahul K Mitra
Publisher: Wolters Kluwer India Pvt. Limited
ISBN: 9389859743
Category : Fiction
Languages : en
Pages : 111
Get Book Here
Book Description
Are some of the theories of OECD and UN around marketing intangibles sacrosanct? The same have been countered through qualitative and quantitative arguments. Quantitative arguments are based upon real life scenarios, with reference to statistical analyses on selected empirical data. Genesis of litigation around marketing intangibles analysed, along with solutions. Concept of royalties for licensed manufacturers explained in the context of regulatory regime of India. Practical solutions provided on harmonisation of transfer pricing and customs duty regulations in complex cases. Concept of attribution of profits to dependent agency permanent establishments explained, with reference to Berry Ratio. Foreword by Dr. Raffalle Dr. Raffaele Petruzzi & Dr. Alfred Storck Professors of Vienna University of Economics and Business
Author: Raffaele Petruzzi
Publisher: Kluwer Law International B.V.
ISBN: 9403535202
Category : Law
Languages : en
Pages : 549
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Book Description
This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following: extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics; specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India; detailed presentation of the use of new technologies by both taxpayers and tax authorities; and further in-depth analysis of transfer pricing’s interaction with various fields of law. With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.
Author: Raffaele Petruzzi
Publisher: Kluwer Law International B.V.
ISBN: 9403540338
Category : Law
Languages : en
Pages : 261
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Book Description
In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions: loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law. Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.
Author: Stewart R Clegg
Publisher: SAGE
ISBN: 1529797489
Category : Business & Economics
Languages : en
Pages : 671
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Book Description
Written by an expert team and praised for its refreshing approach, this essential text offers a critical, holistic understanding of strategy theory and practice. The fourth edition has been fully updated to include: • Coverage of contemporary issues including the Covid-19 pandemic, climate change and digitalization • Topical and engaging case studies such as Disney’s Strategy and Covid-19, Netflix Versus Amazon: Dynamic Capabilities for Global Success, and PS5, Xbox and BMW: Chips and Supply Chains • A wealth of new examples of strategy in practice from world-renowned organisations such as Google, Uniqlo, Tesla, IKEA, and Airbnb Suitable for both undergraduate and postgraduate study, Strategy: Theory and Practice encourages readers to engage critically with the internal and external factors that shape strategy in the real world. A selection of tried and tested online resources, including a teaching guide, PowerPoints, an online case study bank and test bank of questions have been developed to support lecturers using the book in their teaching. Stewart Clegg is Professor at the University of Sydney, Emeritus Professor at the University of Technology Sydney, and Visiting Professor at the University of Stavanger, University of Johannesburg, and Nova School of Business and Economics. Christos Pitelis is Head of Department of International Business and Professor of International Business and Sustainable Competitiveness at the University of Leeds, and Life Fellow at Queens’ College, University of Cambridge. Jochen Schweitzer is an Associate Professor at the University of Technology Sydney. Andrea Whittle is Professor of Management at Newcastle University Business School.
Author:
Publisher:
ISBN:
Category :
Languages : en
Pages : 122
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Book Description
InfoWorld is targeted to Senior IT professionals. Content is segmented into Channels and Topic Centers. InfoWorld also celebrates people, companies, and projects.
Author: Smarak Swain
Publisher:
ISBN: 9789389702743
Category : Fiction
Languages : en
Pages : 706
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Book Description
This book provides a practical and technical guide to tax treatment and transfer pricing of intangibles such as patents, knowhow, copyrights, trademarks, exploitation rights etc. Starting with the issues involved in identification and taxation of transactions in intangibles and rights, the book goes on to discuss the nuances of finding the Arm's length range of royalty rates, IP transfer, hard to value intangibles, marketing intangibles, corporate guarantee, and Value at risk. There is a dearth of literature on the practical aspects of Income Tax and transfer pricing practice; this book seeks to rectify that. The book discusses methods and models of benchmarking of intangibles, and goes on to demonstrate - step by step - how these methods and models can be used to arrive at the Arm's length standard. The nuances arising from assessment and litigation trends have also been highlighted. Other issues covered in the book are taxation of digital economy, tax treatment of cryptocurrencies, and taxation of intangibles under GST.
Author: Vescovi, Tiziano
Publisher: Edward Elgar Publishing
ISBN: 1800889755
Category : Business & Economics
Languages : en
Pages : 352
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Book Description
Viewing Europe as the centre of intercultural confrontation with its own set of subcultures, Cross-Cultural Marketing analyses the cultural comparison between East and West from a European perspective. Structured in four parts, the textbook explores the cross-cultural approach; a model of cross-cultural marketing strategy; marketing choices and decisions, and cross-cultural marketing challenges. At the end of each part, business cases and intercultural stories pose challenging questions for students’ discussion.
Author:
Publisher:
ISBN:
Category : Electronics
Languages : en
Pages : 978
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Book Description
Author:
Publisher:
ISBN:
Category :
Languages : en
Pages : 72
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Book Description
InfoWorld is targeted to Senior IT professionals. Content is segmented into Channels and Topic Centers. InfoWorld also celebrates people, companies, and projects.
Author:
Publisher:
ISBN:
Category : Transportation
Languages : en
Pages : 336
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Book Description
