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Vol 23 No 3 March/April 2018

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This book is now Out of Print.
A new edition has been published, the details can be seen here:
Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies 7th ed isbn 9789041190499

Guide to International Transfer Pricing: Law, Tax Planning and Compliance Strategies 6th ed

Edited by: Duff & Phelps, A. Michael Heimert, T. J. Michaelson

ISBN13: 9789041169082
New Edition ISBN: 9789041190499
Previous Edition ISBN: 9789041161246
Published: September 2016
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Paperback
Price: Out of print

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.

List of Abbreviations

CHAPTER 1 Overview/Best Practices
Michelle Johnson, Justin Radziewicz & Uday Singh
CHAPTER 2 OECD Transfer Pricing Guidelines
Andrew Cousins & Danny Beeton
CHAPTER 3 Argentina
Matías Federico Lozano & Cristian E. Rosso Alba
CHAPTER 4 Australia
Shannon Smit & Adriana Calderon
CHAPTER 5 Belgium
Natalie Reypens
CHAPTER 6 Brazil
Luís Rogério Farinelli, Cristiane M.S. Magalhães, Stephanie Makin & Amanda Alves Brandão.
CHAPTER 7 Canada
Jennifer Shulman
Glenn DeSouza
CHAPTER 9 France
Félicie Bonnet & Arnaud Le Boulanger
CHAPTER 10 Germany
Angelika Thies
CHAPTER 11 Ireland
Joe Duffy & Barry McGettrick
CHAPTER 12 Israel
Jonathan Lubick
CHAPTER 13 Italy
Marco Valdonio, Aurelio Massimiano & Mirko Severi
CHAPTER 14 Mexico
Yoshio Uehara & Gustavo Méndez
CHAPTER 15 The Netherlands
Rogier Sterk & Patrick van Oppen
CHAPTER 16 South Korea
Tae Yeon (TY) Nam, Jae Suk (JS) Park & Christopher Sung
CHAPTER 17 United Kingdom
Shiv Mahalingham
CHAPTER 18 United States
Jill Weise, Stefanie Perrella & Rod Koborsi

ANNEX I Transfer Pricing Rules Summary
ANNEX II Transfer Pricing Implementation Checklist
Table of Cases