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Wildy’s Book News

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Vol 22 No 8 August/Sept 2017

Book of the Month

Cover of STEP: A Practical Guide to the Transfer of Trusteeships

STEP: A Practical Guide to the Transfer of Trusteeships

Edited by: Richard Williams, Arabella Murphy, Toby Graham
Price: £110.00

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Transfer Pricing and the Arm's Length Principle After BEPS


ISBN13: 9780198802914
Published: August 2017
Publisher: Oxford University Press
Country of Publication: UK
Format: Hardback
Price: £125.00



In stock.

This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project.

The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS project, and describes the principal problems that had arisen with those rules.

The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'.

Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and the problems that remain after BEPS. It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic.

This book is the most detailed and up-to-date publication on this highly topical and often controversial topic.

Subjects:
Taxation
Contents:
Introduction
1: The Emergence of the ALP
2: The Development of the ALP
3: Practical Application of the Arm's Length Principle
4: Practical and Theoretical Problems Encountered in Applying the Arm's Length Principle
5: Capital
6: BEPS Modifications to Transfer Pricing Rules
7: Evaluation of BEPS Transfer Pricing Measures
8: Prospects for the ALP After BEPS;