Language : English
Published : 2017-10-02
Pages : 1024
Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies 7th Edition
In Guide to International Transfer Pricing, global practitioners address both the general issues that surround transfer pricing, including the Organisation for Economic Co-operation of Development’s (OECD) fifteen-item Base Erosion and Profit Shifting (BEPS) plan and the specific rules and issues that any company must concern itself with in various jurisdictions around the world. Tax authorities around the globe are increasingly scrutinizing the intercompany pricing practices of taxpayers and enacting rules and regulations to ensure an appropriate allocation of income among the various tax jurisdictions in which a multinational company operates. In addition, a growing number of tax authorities have established documentation requirements to demonstrate appropriate transfer pricing policies, with penalty provisions for non-compliance. Not only must a multinational company understand the different nuances in the transfer pricing laws and their practical interpretation in each local country, but it must also appreciate that by operating in jurisdictions with varying tax rates, transactional structures or intercompany pricing policies can impact the multinational’s global effective tax rate.
What’s in this book:
This guide is a collaboration of many transfer pricing experts from around the world with experience gained from assisting multinationals in implementing planning and compliance strategies, and their insights into dealing with local tax authorities. Key features of this book include:
- overview of fundamental concepts applied in transfer pricing;
- country-specific profiles that compare and contrast rules and real-world applications over multiple jurisdictions, including those likely to adopt BEPS; and
- practical guidance and implementation, enabling the reader to execute a coordinated, cost-effective approach to global policies and documentation needs.
How this will help you:
This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters, covering domestic transfer pricing issues in a variety of key national jurisdictions. The primary objective of this book is to arm the constituents impacted by transfer pricing, including tax directors, legal counsel, accounting and operations personnel, CFOs and outside advisors, with the knowledge base and resources needed for effective transfer pricing decision-making.
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A Practitioner’s Guide to The City Code on Takeovers and Mergers is the definitive, annually updated guide to the work of the Takeover Panel. It describes the role and purpose of the Panel, then examines and gives guidance on all the rules, explaining the responsibilities and actions of each party. It is essential reading for anyone active in mergers and acquisitions.
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For ten boom-powered years at the turn of the twenty-first century, some of America’s most prominent law and accounting firms created and marketed products that enabled the very rich — including newly minted dot-com millionaires — to avoid paying their fair share of taxes by claiming benefits not recognized by law. These abusive domestic tax shelters bore such exotic names as BOSS, BLIPS, and COBRA and were developed by such prestigious firms as KPMG and Ernst & Young. They brought in hundreds of millions of dollars in fees from clients and bilked the U.S. Treasury of billions in revenues before the IRS and Justice Department stepped in with civil penalties and criminal prosecutions. In Confidence Games, Tanina Rostain and Milton Regan describe the rise and fall of the tax shelter industry during this period, offering a riveting account of the most serious episode of professional misconduct in the history of the American bar. Rostain and Regan describe a beleaguered IRS preoccupied by attacks from antitax and antigovernment politicians; heightened competition for professional services; the relaxation of tax practitioner norms against aggressive advice; and the creation of complex financial instruments that made abusive shelters harder to detect. By 2004, the tax shelter boom was over, leaving failed firms, disgraced professionals, and prison sentences in its wake. Rostain and Regan’s cautionary tale remains highly relevant today, as lawyers and accountants continue to face intense competitive pressure and regulators still struggle to keep pace with accelerating financial risk and innovation.
About the Author
Tanina Rostain is Professor of Law and Research Director of the Center for the Study of the Legal Profession at Georgetown Law School. Milton C. Regan, Jr., is Codirector of the Center for the Study of the Legal Profession and McDevitt Professor of Jurisprudence at Georgetown Law School.
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