[PDF] Transfer Pricing In Manufacturing eBook

Author : Ioana Ignat
Publisher : Springer Nature
Page : 196 pages
File Size : 48,14 MB
Release : 2022-05-09
Category : Business & Economics
ISBN : 3030938891

GET BOOK

Transfer pricing is considered a new and complex concept in terms of guidelines and regulations. In this context, more and more academics and tax professionals are interested in understanding the mechanism of a transfer pricing analysis. The main objective of the book is to help them in this process by presenting in a practical approach (using case studies and schemes) and in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations the way in which are operating the basic transfer pricing elements. Moreover, considering that the manufacturing sector is the chief wealth-producing sector of the global economy, the book illustrates complete transfer pricing analyses applicable for manufacturing transactions (using Orbis database). In the end, the book presents some recent disputes between manufacturing entities and tax authorities in relation to the transfer pricing analysis for manufacturing transactions. Chapter “TAMSAT” is available open access under a Creative Commons Attribution 4.0 International License via link.springer.com.

Author : David B. Blair
Publisher :
Page : 0 pages
File Size : 39,61 MB
Release : 2017-05-07
Category : Double taxation
ISBN : 9781402428456

GET BOOK

The phenomena of increasingly global business enterprises with valuable intangible property expose companies to transfer pricing enforcement by different countries around the world. Many of these countries are increasingly aggressive in enforcing their local transfer pricing rules, as they attempt to protect their tax revenue base. To avoid double taxation of the same income in this environment, companies often are required to deal with the highly specialized, bilateral treaty-based competent authority process developed to prevent double taxation at a time when trade mainly involved only two established countries. Even more challenging today, companies and tax authorities increasingly are faced with the potential for multiple taxation of the same income, as supply chains cross many borders and as the tax authorities of emerging countries become players in the global taxation process, and the resulting stresses, strains, and limitations of the bilateral treaty-based competent authority process have become more apparent. In light of the high-dollar risks presented by the increased enforcement efforts of tax authorities worldwide, the complexity of the ever-changing, inherently uncertain transfer pricing standards, and the continually evolving business models of businesses adapting to the constantly changing global economy, companies need practical guidance to permit them to develop and defend their transfer pricing strategies. Transfer Pricing Answer Book gives companies such guidance by discussing all aspects of transfer pricing, from initially planning a transfer pricing strategy, to alternative ways to defend the strategy from attack by two or more tax authorities, to resolving a case before competent authorities, to bringing a transfer pricing case to court. The book's non-technical discussion is presented in a question and answer format that will appeal to readers regardless of their prior level of experience or familiarity with taxes in general and transfer pricing in particular. Transfer Pricing Answer Book is an invaluable resource for company executives and their advisors who are seeking to better understand this important area of tax law that has become such an important economic facet of so many businesses.

Author : M.R.U.D. Tambunan
Publisher :
Page : pages
File Size : 41,94 MB
Release : 2020
Category :
ISBN :

GET BOOK

The article considers transfer pricing disputes in the manufacturing industry arising from administrative and technical aspects that were settled in the Indonesian Tax Court during the fiscal years 2015-2019. The most common disputes are: (i) selection of comparable data and transfer pricing method; (ii) inappropriate assessment process following the applicable rule; and (iii) different methods to assess the arm's length principle.

Author : John Abrahamson
Publisher : Kluwer Law International B.V.
Page : 498 pages
File Size : 27,45 MB
Release : 2016-02-18
Category : Law
ISBN : 904116667X

GET BOOK

The most thorough treatment of its subject available, this book introduces and analyses the international tax issues relating to international manufacturing and distribution activities, extending from the tax regime in the country where the manufacturing activities are located, through to regional purchase and sales companies, to the taxation of local country sales companies. The analysis includes the domestic tax laws relating to manufacturing and distribution company profits as well as international tax issues relating to income flows and the payment of dividends. Among the topics and issues analysed in depth are the following: – foreign tax credits; – taxation in the digital economy; – tax incentives; – intellectual property; – group treasury companies; – mergers and acquisitions; – leasing; – derivatives; – controlled foreign corporation provisions; – VAT and customs tariffs; – free trade agreements and customs unions; – transfer pricing; – role of tax treaties; – hedging; – related accounting issues; – deferred tax assets and liabilities; – tax risk management; – supply chain management; – depreciation allowances; and – carry-forward tax losses. The book includes descriptions of 21 country tax systems and ten detailed case studies applying the analysis to specific examples. Detailed up-to-date attention is paid to the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and other measures against tax avoidance. As a full-scale commentary and analysis of international taxation issues for multinational manufacturing groups – including in-depth consideration of corporate structures, tax treaties, transfer pricing, and current developments – this book is without peer. It will prove of inestimable value to all accountants, lawyers, economists, financial managers, and government officials working in international trade environments.

Author : R. Dorward
Publisher :
Page : pages
File Size : 16,82 MB
Release : 2017
Category :
ISBN :

GET BOOK

This article examines how 3-D printing could cause companies to radically restructure their supply chains and the impact of that restructuring on transfer pricing compliance.

Author : OECD
Publisher : OECD Publishing
Page : 612 pages
File Size : 50,27 MB
Release : 2017-07-10
Category :
ISBN : 9264265120

GET BOOK

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 : OECD
Publisher : OECD Publishing
Page : 658 pages
File Size : 49,97 MB
Release : 2022-01-20
Category :
ISBN : 9264921915

GET BOOK

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.