The Taxation of Global Trading of Financial Instruments

The Taxation of Global Trading of Financial Instruments PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264162496
Category :
Languages : en
Pages : 71

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Book Description
This publication thoroughly reviews the factual background to global trading, analyses the challenges posed to traditional taxation methods and discusses a range of policy options to tackle the problems.

The Taxation of Global Trading of Financial Instruments

The Taxation of Global Trading of Financial Instruments PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264162496
Category :
Languages : en
Pages : 71

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Book Description
This publication thoroughly reviews the factual background to global trading, analyses the challenges posed to traditional taxation methods and discusses a range of policy options to tackle the problems.

Introduction to Transfer Pricing

Introduction to Transfer Pricing PDF Author: Jerome Monsenego
Publisher:
ISBN: 9789144092706
Category : Business & Economics
Languages : en
Pages : 163

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Book Description
Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 PDF 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.

Transfer Pricing and Intra-group Financing

Transfer Pricing and Intra-group Financing PDF 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.

United Nations Practical Manual on Transfer Pricing for Developing Countries 2017

United Nations Practical Manual on Transfer Pricing for Developing Countries 2017 PDF Author: United Nations
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 672

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Book Description
The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.

International Taxation of Banking

International Taxation of Banking PDF Author: John Abrahamson
Publisher: Kluwer Law International B.V.
ISBN: 9403510951
Category : Law
Languages : en
Pages : 468

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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.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 PDF 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.

The Taxation of Global Trading of Financial Instruments

The Taxation of Global Trading of Financial Instruments PDF Author: Organisation for Economic Co-operation and Development. Special Sessions on Innovative Financial Transactions
Publisher: Organisation for Economic Co-operation and Development
ISBN:
Category : Business & Economics
Languages : en
Pages : 80

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Book Description
Document released for public comment. Includes transfer pricing.

International Transfer Pricing

International Transfer Pricing PDF 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.

Transfer Pricing and Corporate Taxation

Transfer Pricing and Corporate Taxation PDF Author: Elizabeth King
Publisher: Springer Science & Business Media
ISBN: 0387781838
Category : Business & Economics
Languages : en
Pages : 199

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Book Description
National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.