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Vol 23 No 3 March/April 2018

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Introduction to Transfer Pricing

ISBN13: 9789041159854
Published: August 2015
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £96.00

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Transfer pricing refers to the pricing of cross-border intercompany transactions. In the context of taxation, the main aim of transfer pricing is to share the income – and thus, the tax base – of multinational enterprises between the countries where they are doing business.

Introduction to Transfer Pricing intends at providing a general introduction to the fundamentals of transfer pricing. The book is focused on explanations of the principles that apply, albeit to various extents, in most countries. Although the majority of these principles is provided by the OECD, the views of other international organisations, in particular the United Nations and the European Union, are also taken into account. Moreover, the book illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when conducting cross-border business activities.

Such examples are intended to facilitate the understanding of transfer pricing principles, and emphasise the tax planning or risk mitigating aspects that may be considered by multinational enterprises and that need to be monitored by tax administrations. Also included are relevant court cases from a variety of countries. Among the issues and topics covered are the following:-

  • the arm’s length principle in theory and practice;
  • transfer pricing methods recognised by the OECD Guidelines;
  • intercompany transactions involving intangibles;
  • common types of intercompany transactions and transfer pricing models;
  • cross-border business restructurings;
  • the substance requirement for transfer pricing purposes;
  • attribution of profits to permanent establishments; and
  • the prevention and resolution of transfer pricing disputes

About the Authors.
List of Abbreviations.
List of Tables.
List of Figures.;
Chapter 1 The Key to Understanding Transfer Pricing: The Arm’s Length Principle.
Chapter 2 The Transfer Pricing Methods Recognised by the OECD Guidelines.
Chapter 3 Transfer Pricing Models.
Chapter 4 Cross-Border Business Restructurings.
Chapter 5 The Substance Requirement from a Transfer Pricing Perspective.
Chapter 6 The Attribution of Profits to Permanent Establishments.
Chapter 7 The Prevention and the Resolution of Transfer Pricing Disputes.
Table of Cases.
Table of Legislation.