This handbook provides a comprehensive analysis of the transfer pricing issues that affect taxpayers and tax collectors alike. It has a practical focus advising taxpayers about transfer pricing techniques and their consequences. * Provides non-tax transfer pricing guidance on such issues as imported merchandise, customs-related issues, and customs appraisement * Describes IRS penalties in detail * Describes various transfer pricing methodologies This core volume (ISBN 0471-406619) is supplemented annually. The 2002 Supplement includes updates to both Transfer Pricing 3e and Transfer Pricing International. It contains: * Two new chapters on Cost-Sharing Buy-Ins and Technology, Licensing, and Economic Issues in Transfer Pricing * Complete revisions to chapters on New Zealand, Singapore, Belgium, Czech Republic, Russia, and South Africa. (with updates to Germany chapter) * New Appendix containing information regarding Practice Note 7 This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).

This book gives an overview of the basic principles of transfer pricing and U.S. transfer pricing rules, and the impact of transfer pricing on other issues such as customs valuation, Section 404 of the Sarbanes-Oxley Act of 2002, and FASB Interpretation no. 48.

This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).

Transfer pricing is the sale, license, or lease of a product from one affiliated company to another. This book takes an international viewpoint and examines U.S. companies doing business abroad as well as foreign-owned corporations. It answers all questions on the often complex issue of transfer pricing. The final treasury regulations on transfer pricing (Section 482) affect all corporations that import and export from their subsidiaries, heavily influencing the value they place on their goods. This clear-cut guide helps corporations to understand and capitalize on the new regulations in order to save up to 39% on their taxes.

Transfer pricing is the sale, license, or lease of a product from one affiliated company to another. This book takes an international viewpoint and examines U.S. companies doing business abroad as well as foreign-owned corporations. It answers all questions on the often complex issue of transfer pricing. The final treasury regulations on transfer pricing (Section 482) affect all corporations that import and export from their subsidiaries, heavily influencing the value they place on their goods. This clear-cut guide helps corporations to understand and capitalize on the new regulations in order to save up to 39% on their taxes.

Transfer pricing is the sale, license, or lease of a product from one affiliated company to another. This book takes an international viewpoint and examines U.S. companies doing business abroad as well as foreign-owned corporations. It answers all questions on the often complex issue of transfer pricing. The final treasury regulations on transfer pricing (Section 482) affect all corporations that import and export from their subsidiaries, heavily influencing the value they place on their goods. This clear-cut guide helps corporations to understand and capitalize on the new regulations in order to save up to 39% on their taxes.

Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.

Transfer pricing is the sale, license, or lease of a product from one affiliated company to another. This book takes an international viewpoint and examines U.S. companies doing business abroad as well as foreign-owned corporations. It answers all questions on the often complex issue of transfer pricing. The final treasury regulations on transfer pricing (Section 482) affect all corporations that import and export from their subsidiaries, heavily influencing the value they place on their goods. This clear-cut guide helps corporations to understand and capitalize on the new regulations in order to save up to 39% on their taxes.

Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.

For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.