Resolving Transfer Pricing Disputes PDF Download
Are you looking for read ebook online? Search for your book and save it on your Kindle device, PC, phones or tablets. Download Resolving Transfer Pricing Disputes PDF full book. Access full book title Resolving Transfer Pricing Disputes by Eduardo Baistrocchi. Download full books in PDF and EPUB format.
Author: Eduardo Baistrocchi
Publisher: Cambridge University Press
ISBN: 1139916289
Category : Law
Languages : en
Pages : 975
Get Book Here
Book Description
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Author: Eduardo Baistrocchi
Publisher: Cambridge University Press
ISBN: 1139916289
Category : Law
Languages : en
Pages : 975
Get Book Here
Book Description
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Author: Anuschka Bakker
Publisher: IBFD
ISBN: 9087221002
Category : Dispute resolution (Law).
Languages : en
Pages : 807
Get Book Here
Book Description
This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.
Author: David Rosenbloom
Publisher:
ISBN:
Category : Dispute resolution (Law)
Languages : en
Pages :
Get Book Here
Book Description
Consists of the first three chapters of the 2011 edition which have been updated based on information available up to 15 September, 1 August, and 31 July 2014, respectively.
Author: S.K. Bilaney
Publisher:
ISBN:
Category :
Languages : en
Pages :
Get Book Here
Book Description
Transfer pricing is one of the most litigious areas of taxation. This article discusses transfer pricing litigation trends in India and various dispute resolution mechanisms available to taxpayers for resolving transfer pricing disputes. In addition, analyses of statistical data relating to results achieved by various dispute resolution mechanisms are also presented.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264169466
Category :
Languages : en
Pages : 110
Get Book Here
Book Description
This report addresses the practical administration of transfer pricing programmes by tax administrations.
Author: G. Capristano Cardoso
Publisher:
ISBN:
Category :
Languages : en
Pages :
Get Book Here
Book Description
In this article, the author considers the use of alternative forms of dispute resolution to resolve tax treaty disputes, focusing on the potential benefits of and obstacles to using mandatory binding arbitration to resolve transfer pricing disputes, including those that may arise under the OECD's Unified Approach for allocating profits in the digital economy.
Author: Dr. (Adv) Priyanka Shokeen
Publisher: Casa Editorial
ISBN: 8197765898
Category : Business & Economics
Languages : en
Pages : 229
Get Book Here
Book Description
This book on Taxation Dispute Resolution Mechanism with Special Reference to International Trade explores the intricate legal and procedural frameworks governing tax-related conflicts in global commerce. It delves into the What is dispute and how it can effect any economy it also delves into intersection of tax law and international trade, analyzing the mechanisms designed to resolve disputes between multinational corporations and tax authorities. Key areas include bilateral and multilateral treaties, such as the OECD Model Tax Convention, and how they address tax evasion, double taxation, and transfer pricing issues. The book also examines arbitration and mediation as effective tools for resolving such disputes, comparing various countries' approaches and international organizations' roles in shaping dispute resolution frameworks. In the context of globalization, your book highlights the growing complexity of tax-related disagreements, emphasizing the need for streamlined processes to promote trade without compromising tax compliance. The work provides a critical analysis of case law, treaties, and dispute settlement mechanisms to guide practitioners, policymakers, and academics.
Author: Michael Lang
Publisher: Kluwer Law International B.V.
ISBN: 9403517247
Category : Law
Languages : en
Pages : 484
Get Book Here
Book Description
Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.
Author: David Rüll
Publisher: Kluwer Law International B.V.
ISBN: 9403520981
Category : Law
Languages : en
Pages : 263
Get Book Here
Book Description
The number of international tax disputes is constantly increasing. This is a logical consequence of the pressure that is exerted on the global tax system by a rise in the number of internationally active and mobile taxpayers and tax competition between states on the one hand. On the other hand, the implementation of measures to tackle base erosion and profit shifting (BEPS) by multinational enterprises already gives rise to further disputes and another increase of disputes might arise from the latest reforms of the international tax system, namely the Two-Pillar-Solution to address the tax challenges arising from the digitalisation of the economy. Against this background, the time is right for an institutionalised international tax dispute resolution mechanism that takes into account the interests of taxpayers, states, and the public and allows for a swift and binding resolution of international tax disputes ¬– exactly what this timely and thoroughgoing book offers. A comprehensive overview of existing international tax dispute resolution mechanisms – and an analysis of their procedural rules, advantages, and disadvantages – leads to a deeply informed proposal on how they can be further developed in a way that ensures greater fairness and equity for all stakeholders. Among the lines of conflict that characterise international tax disputes, the author sheds clear light on how improvements in the design of dispute resolution mechanisms may be found. This includes these questions: How should a dispute resolution mechanism be structured? Should there be a mandatory resolution if the states cannot agree? In which way should taxpayers participate in the procedure? Should agreements and decisions be published? Should there be an institution to administer the procedure? The book concludes with a draft convention that would implement the author’s suggestions. Tax lawyers and other tax professionals worldwide, as well as national tax authorities, will benefit greatly from this book. They will deepen their understanding of the variety of existing tax dispute resolution mechanisms and discover ways to strengthen them. Academics will find ample room to reflect on the key design elements of such mechanisms and how to improve them.
Author: Zvi Daniel Altman
Publisher: IBFD
ISBN: 9076078947
Category : Arbitration and award, International
Languages : en
Pages : 498
Get Book Here
Book Description
As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
