Transfer Pricing and Value Creation 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 Transfer Pricing and Value Creation PDF full book. Access full book title Transfer Pricing and Value Creation by Raffaele Petruzzi. Download full books in PDF and EPUB format.
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: 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 :
Get Book
Book Description
Author: Werner C. Haslehner
Publisher:
ISBN: 9789087226893
Category : Commercial law
Languages : en
Pages :
Get Book
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
Get Book
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: Raffaele Petruzzi
Publisher:
ISBN: 9783707341232
Category :
Languages : en
Pages : 556
Get Book
Book Description
Author: Werner Haslehner
Publisher: Kluwer Law International B.V.
ISBN: 9403503351
Category : Law
Languages : en
Pages : 370
Get Book
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
Get Book
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: Daniela Venanzi
Publisher: Springer Science & Business Media
ISBN: 884702451X
Category : Business & Economics
Languages : en
Pages : 81
Get Book
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: Ray Ball
Publisher:
ISBN: 9780858234253
Category : Natural resources
Languages : en
Pages : 29
Get Book
Book Description
Author: Pablo Fernandez
Publisher: Academic Press
ISBN: 0122538412
Category : Business & Economics
Languages : en
Pages : 662
Get Book
Book Description
This text provides a catalogue of valuation tools, together with guidance on analyzing and valuing a business. The author breaks down the topic to provide advice for any business, no matter how complex. He presents eight different methods of firm valuation and discusses the benefits and limitations of each method, supporting this information with examples from international markets.
