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Transfer Pricing in the US: A Practical Guide


ISBN13: 9789041191960
Published: September 2017
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £113.00



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Transfer Pricing in the US is the best and most up-to-date summary of transfer pricing practices available today. In the twenty-first century economy, where multinational enterprises are dominant players, transfer pricing—pricing goods and services transferred within a multinational or transnational company in order to reduce tax burdens and maximize profits—has become the new game. Although transfer pricing is not per se illegal or abusive, in practice its manipulation facilitates large-scale tax evasion and has thus become a major concern of revenue authorities worldwide. This concise but comprehensive analysis focuses on how the United States (US), home of most of the multinationals engaging in abundant and complex transfer pricing arrangements, approaches the task of combating the abusive transfer pricing machinery.

What’s in this book:

Offering practical advice and strategies, illustrated by real case studies, the author explains the key aspects and technicalities of US transfer pricing and the impact of international issues, including such aspects of the subject as the following:

  • types of transfer pricing methods and pricing agreements among subsidiaries and affiliates;
  • cost-sharing arrangements;
  • services transactions;
  • European Union tax treatment of US-based multinationals;
  • Organisation for Economic Co-operation and Development’s (OECD’s) Transfer Pricing Guidelines and Base Erosion and Profit Shifting initiative;
  • companies’ preparedness for country-by-country reporting;
  • intellectual property migration; and
  • documentation and penalties.
The book begins with a general introduction to transfer pricing and then discusses the current OECD’s Transfer Pricing Guidelines, which form the basis for most transfer pricing rules around the world. The book describes in detail the approved methods for tangible and intangible property, cost sharing, services and the best method rule. Then the book discusses functional analysis for the various methods, including the necessary documentation and penalty rules.

How this will help you:

This concise, practical guide to the latest issues in the rapidly evolving legal regime on transfer pricing in the US context fills the need to gain a firm grasp of transfer pricing rules and practice for corporate counsel and practitioners worldwide, enabling them to prepare compliant solutions and strategies and avoid pitfalls. This book is an indispensable resource for practitioners and academics, and it will be very useful to state tax authorities.

Subjects:
Other Jurisdictions , Taxation, USA
Contents:
About the Author
Disclaimer
Foreword
List of Abbreviations
List of Figures
CHAPTER 1 Overview of Transfer Pricing
CHAPTER 2 The OECD Transfer Pricing Guidelines
CHAPTER 3 The US Transfer Pricing Approach
CHAPTER 4 Transfer Pricing for Tangible Property
CHAPTER 5 Transfer Pricing for Intangible Property
CHAPTER 6 Cost Sharing Arrangements
CHAPTER 7 Transfer Pricing for Services
CHAPTER 8 The Best Method Rule
CHAPTER 9 Functional Analysis
CHAPTER 10 Documentation and Penalties
CHAPTER 11 Advance Pricing and Mutual Agreement
CHAPTER 12 Transfer Pricing and Base Erosion and Profit Shifting
CHAPTER 13 The EU Illegal Aid and Transfer Pricing
CHAPTER 14 Transfer Pricing in Business Restructurings
Bibliography
Table of Cases
Glossary
Index

Series: EUCOTAX Series on European Taxation

Aggrieved Taxpayers versus Tax Authorities ISBN 9789403522081
To be published May 2024
Kluwer Law International
£111.00
(ePub)
Buy
£111.00
Special Tax Zones and EU Law: Theory, Implementations and Future Challenges ISBN 9789403518855
Published January 2020
Kluwer Law International
£112.00
European VAT and the Sharing Economy ISBN 9789403514352
Published October 2019
Kluwer Law International
£116.00
£86.00
Sales Promotion Techniques and VAT in the EU ISBN 9789403508610
Published March 2019
Kluwer Law International
£115.00
£111.00
Investment Fund Taxation: Domestic Law, EU Law, and Double Taxation Treaties ISBN 9789041196699
Published May 2018
Kluwer Law International
£107.00
National Legal Presumptions and European Tax Law ISBN 9789041166135
Published February 2018
Kluwer Law International
£154.00
Double (Non-) Taxation and EU Law ISBN 9789041194107
Published November 2017
Kluwer Law International
£167.00
EU Citizenship and Direct Taxation ISBN 9789041185846
Published October 2017
Kluwer Law International
£139.00
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed ISBN 9789041161352
Published September 2017
Kluwer Law International
£188.00
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed (eBook) ISBN 9789041161437
Published September 2017
Kluwer Law International
£188.00
(ePub)
Buy
The Impact of Tax Treaties and EU Law on Group Taxation Regimes ISBN 9789041169051
Published August 2016
Kluwer Law International
£211.00
£142.00
(ePub)
Buy
Corporate Tax Base in the Light of IAS/IFRS and EU Directive 2013/34: A Comparative Approach ISBN 9789041167453
Published July 2016
Kluwer Law International
£142.00
Tax Treaty Override ISBN 9789041154064
Published April 2014
Kluwer Law International
£167.00
Fixed Establishments in European VAT ISBN 9789041145543
Published August 2013
Kluwer Law International
£154.00
CCCTB: Common Consolidated Corporate Tax Base - Selected Issues (EUCOTAX 35)
Edited by: Dennis Weber
ISBN 9789041138729
Published May 2012
Kluwer Law International
£178.00
Intermediation of Insurance & Financial Services in European VAT ISBN 9789041137326
Published August 2011
Kluwer Law International
£178.00
From Marks & Spencer to X Holding: The Future of Cross-Border Group Taxation ISBN 9789041133991
Published August 2011
Kluwer Law International
£167.00
Fiscal Sovereignty of the Member States in an Internal Market: Past and Future ISBN 9789041134035
Published December 2010
Kluwer Law International
£167.00
Europe-China Tax Treaties ISBN 9789041132161
Published June 2010
Kluwer Law International
£167.00
Taxation of Ucits: Austria Germany the Netherlands and the Uk ISBN 9789041128393
Published October 2009
Kluwer Law International
£173.00
Integration Approaches to Group Taxation in European Internal Market ISBN 9789041127792
Published October 2008
Kluwer Law International
£167.00
Tax Compliance Costs for Companies in an Enlarged European Community ISBN 9789041126665
Published May 2008
Kluwer Law International
£224.00
ECJ-Recent Developments in Direct Taxation ISBN 9789041125095
Published March 2006
Kluwer Law International
£177.00
Limitation on Benefits Clauses in Double Taxation Conventions ISBN 9789041123701
Published December 2005
Kluwer Law International
Out of print
Tax Avoidance and EC Treaty Freedoms ISBN 9789041124029
Published December 2005
Kluwer Law International
£222.00
WTO and Direct Taxation ISBN 9789041123718
Published May 2005
Kluwer Law International
£374.00
£187.00
Tax Competition and EU Law
Carlo PintoResearch Associate, Department of Law, University of Amsterdam, Netherlands
ISBN 9789041199133
Published May 2003
Kluwer Law International
£290.00
Settlement of Disputes in Tax Treaty Law ISBN 9789041199041
Published September 2002
Kluwer Law International
£298.00
Tax Treaty Interpretation
Edited by: Michael Lang
ISBN 9789041198570
Published June 2002
Kluwer Law International
£249.00
The Impact of Community Law on Tax Treaties: Issues and Solutions ISBN 9789041198600
Published February 2002
Kluwer Law International
£268.00
The Principle of Equality in European Taxation ISBN 9789041196934
Published October 1999
Kluwer Law International
£243.00
The Compatibility of Anti-abuse Provisions in Tax Treaties with EC Law
ISBN 9789041196781
Published January 1999
Kluwer Law International
£262.00