Transfer Pricing in Manufacturing

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  • Publisher : Springer Nature
  • Release : 09 December 2022
  • ISBN : 9783030938895
  • Page : 196 pages
  • Rating : 4.5/5 from 103 voters

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Transfer pricing is considered a new and complex concept in terms of guidelines and regulations. In this context, more and more academics and tax professionals are interested in understanding the mechanism of a transfer pricing analysis. The main objective of the book is to help them in this process by presenting in a practical approach (using case studies and schemes) and in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations the way in which are operating the basic transfer pricing elements. Moreover, considering that the manufacturing sector is the chief wealth-producing sector of the global economy, the book illustrates complete transfer pricing analyses applicable for manufacturing transactions (using Orbis database). In the end, the book presents some recent disputes between manufacturing entities and tax authorities in relation to the transfer pricing analysis for manufacturing transactions. Chapter TAMSAT is available open access under a Creative Commons Attribution 4.0 International License via link.springer.com.

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Transfer Pricing in Manufacturing

Transfer Pricing in Manufacturing
  • Author : Ioana Ignat,Liliana Ionescu-Feleagă
  • Publisher : Springer Nature
  • Release Date : 2022
  • ISBN : 9783030938895
GET THIS BOOKTransfer Pricing in Manufacturing

Transfer pricing is considered a new and complex concept in terms of guidelines and regulations. In this context, more and more academics and tax professionals are interested in understanding the mechanism of a transfer pricing analysis. The main objective of the book is to help them in this process by presenting in a practical approach (using case studies and schemes) and in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations the way in which are

Fundamentals of Transfer Pricing

Fundamentals of Transfer Pricing
  • Author : Raffaele Petruzzi,Giammarco Cottani,Michael Lang
  • Publisher : Kluwer Law International B.V.
  • Release Date : 2022-06-20
  • ISBN : 9789403535203
GET THIS BOOKFundamentals of Transfer Pricing

This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines. As in the first volume,

Critical Concerns in Transfer Pricing and Practice

Critical Concerns in Transfer Pricing and Practice
  • Author : Wagdy Moustafa Abdallah
  • Publisher : Greenwood Publishing Group
  • Release Date : 2004
  • ISBN : 9781567205619
GET THIS BOOKCritical Concerns in Transfer Pricing and Practice

For multinational corporations (MNCs), there is arguably no more important operational function that affects all areas of manufacturing, marketing, management, and finance as international transfer pricing--the practicing of supplying products or services across borders from one part of the organization to another. Its complexity is compounded by the impact of e-commerce, speeding the flow of goods and services; "intangible" assets, such as intellectual property, whose value is difficult to quantify; and the activites of policymakers around the world to update

Transfer Pricing Methods

Transfer Pricing Methods
  • Author : Robert Feinschreiber
  • Publisher : John Wiley & Sons
  • Release Date : 2004-03-15
  • ISBN : 9780471651239
GET THIS BOOKTransfer Pricing Methods

Advanced praise for Transfer Pricing Methods "Feinschreiber and a team of renowned executives have provided thedefinitive transfer-pricing guide to this challenging area. At atime when many companies are reviewing documents, policies, andprocedures, it's wonderful to have a concise, clearly writtenreference focused on what may be the most critical corporate taxissue." -Charles R. Goulding, Managing Director, Tax Cooper Industries, Inc. "It is refreshing to find a treatise on transfer pricing thatcombines practical business considerations, economic theory, and adiscussion of technical tax

Transfer Pricing and Business Restructurings

Transfer Pricing and Business Restructurings
  • Author : Anuschka Bakker
  • Publisher : IBFD
  • Release Date : 2009
  • ISBN : 9789087220556
GET THIS BOOKTransfer Pricing and Business Restructurings

This book highlights the main tax issues that arise when business restructurings take place. It provides fundamental information about the drivers of business restructurings and business models, examines the application of Art. 9 of the OECD Model Convention, and considers not only the direct tax issues in business restructuring, but also VAT and customs duties. It gives practical insights into the tax accounting treatment of business restructurings, OECD work in progress and the effect of the EU tax system, and includes

Transfer Pricing and Developing Economies

Transfer Pricing and Developing Economies
  • Author : Joel Cooper,Randall Fox,Jan Loeprick,Komal Mohindra
  • Publisher : World Bank Publications
  • Release Date : 2017-01-05
  • ISBN : 9781464809705
GET THIS BOOKTransfer Pricing and Developing Economies

Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices

Transfer Pricing and Value Creation

Transfer Pricing and Value Creation
  • Author : Raffaele Petruzzi,Romero J.S. Tavares Esq.
  • Publisher : Linde Verlag GmbH
  • Release Date : 2019-09-02
  • ISBN : 9783709410387
GET THIS BOOKTransfer Pricing and Value Creation

Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and

Introduction to Transfer Pricing

Introduction to Transfer Pricing
  • Author : Jérôme Monsenego
  • Publisher : Unknown
  • Release Date : 2015
  • ISBN : 9041159851
GET THIS BOOKIntroduction to Transfer Pricing

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 è^' and thus, the tax base è^' of multinational enterprises between the countries where they are doing business. The importance of transfer pricing has significantly expanded over the last few decades. With the globalisation of business activities, the need for States to monitor transfer prices so as to avoid the illegitimate erosion of their

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017
  • Author : OECD
  • Publisher : OECD Publishing
  • Release Date : 2017-07-10
  • ISBN : 9789264265127
GET THIS BOOKOECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

Transfer Pricing in China

Transfer Pricing in China
  • Author : Jian Li,Alan Paisey
  • Publisher : Springer
  • Release Date : 2019-05-30
  • ISBN : 9789811376894
GET THIS BOOKTransfer Pricing in China

This book offers up to date insights into the exciting world of China’s extensive economic activity through the pervasive and often secretive practice of transfer pricing. It begins with an explanation of transfer pricing itself and goes on to explore how intricately it can infiltrate the trading practices of the commercial lives of both foreign companies in China and Chinese companies expanding to other countries. A review of the main industries in China also considers their possible future uncertainties.

Transfer Pricing in One Lesson

Transfer Pricing in One Lesson
  • Author : Oliver Treidler
  • Publisher : Springer Nature
  • Release Date : 2019-09-12
  • ISBN : 9783030250850
GET THIS BOOKTransfer Pricing in One Lesson

This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm’s length

Transfer Pricing

Transfer Pricing
  • Author : Studio Trivoli Staff
  • Publisher : Springer
  • Release Date : 2014-04-20
  • ISBN : 9401745188
GET THIS BOOKTransfer Pricing

As a part of the provisions governing the subject of the measurement of the income of business enterprises, the fifth paragraph, sub paragraph b), of article 53 of the Presidential Decree no. 597 of 29 September, 1973, provides, as it is well known, that "the difference between the normal value of goods and services, and the consideration for transfers made and for services rendered to companies, whose legal seat or administrative headquarters and whose main object are not in the Italian territory, and which

Multinationals and Transfer Pricing

Multinationals and Transfer Pricing
  • Author : Alan M. Rugman,Lorraine Eden
  • Publisher : Routledge
  • Release Date : 2017-02-03
  • ISBN : 9781351999687
GET THIS BOOKMultinationals and Transfer Pricing

One of the reasons for the success of multinational enterprises in their ability to create in their supranational organisations "internal markets" which eliminate the imperfections of external world markets caused by tariffs on trade, restrictions on the flow of capital, information costs and so on. The method multinationals use to create and sustain internal markets is transfer pricing. Multinationals use to their advantage the difference between nominal accounting and real transfers from their head offices to a subsidiary in different

Introduction to Transfer Pricing, Second Edition

Introduction to Transfer Pricing, Second Edition
  • Author : Jerome Monsenego
  • Publisher : Kluwer Law International B.V.
  • Release Date : 2022-11-22
  • ISBN : 9789403514932
GET THIS BOOKIntroduction to Transfer Pricing, Second Edition

Transfer pricing refers to the pricing of cross-border intercompany transactions. Transfer prices influence the tax base of multinational enterprises, and thus also the fiscal revenues of the countries where they are doing business. The importance of transfer pricing has significantly expanded over time and culminated with the work of the OECD on Base Erosion and Profit Shifting (BEPS). With the globalisation of business activities, the need for States to prevent tax avoidance, and the risk of double taxation faced by

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022
  • Author : OECD
  • Publisher : OECD Publishing
  • Release Date : 2022-01-20
  • ISBN : 9789264921917
GET THIS BOOKOECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.