Multinationals And Transfer Pricing
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Author |
: Alan M. Rugman |
Publisher |
: Routledge |
Total Pages |
: 292 |
Release |
: 2017-02-03 |
ISBN-10 |
: 9781351999687 |
ISBN-13 |
: 1351999680 |
Rating |
: 4/5 (87 Downloads) |
Synopsis Multinationals and Transfer Pricing by : Alan M. Rugman
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 countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals’ use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.
Author |
: Lorraine Eden |
Publisher |
: University of Toronto Press |
Total Pages |
: 788 |
Release |
: 1998-01-01 |
ISBN-10 |
: 0802007767 |
ISBN-13 |
: 9780802007766 |
Rating |
: 4/5 (67 Downloads) |
Synopsis Taxing Multinationals by : Lorraine Eden
Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.
Author |
: OECD |
Publisher |
: OECD Publishing |
Total Pages |
: 612 |
Release |
: 2017-07-10 |
ISBN-10 |
: 9789264265127 |
ISBN-13 |
: 9264265120 |
Rating |
: 4/5 (27 Downloads) |
Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 by : OECD
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.
Author |
: OECD |
Publisher |
: OECD Publishing |
Total Pages |
: 658 |
Release |
: 2022-01-20 |
ISBN-10 |
: 9789264921917 |
ISBN-13 |
: 9264921915 |
Rating |
: 4/5 (17 Downloads) |
Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 by : OECD
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.
Author |
: OECD |
Publisher |
: OECD Publishing |
Total Pages |
: 107 |
Release |
: 1979-06-01 |
ISBN-10 |
: 9789264167773 |
ISBN-13 |
: 9264167773 |
Rating |
: 4/5 (73 Downloads) |
Synopsis Transfer Pricing and Multinational Enterprises by : OECD
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises. Following this original 1979 publication, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in this 2009 edition, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. A subsequent edition was released in 2010, in which, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines. Digitised document - Electronic release on 24/11/2011.
Author |
: OECD |
Publisher |
: OECD Publishing |
Total Pages |
: 90 |
Release |
: 1984-10-01 |
ISBN-10 |
: 9789264167803 |
ISBN-13 |
: 9264167803 |
Rating |
: 4/5 (03 Downloads) |
Synopsis Transfer Pricing and Multinational Enterprises Three Taxation Issues by : OECD
Digitised document - Electronic release on 24/11/2011
Author |
: OECD |
Publisher |
: OECD Publishing |
Total Pages |
: 192 |
Release |
: 2017-07-31 |
ISBN-10 |
: 9789264279964 |
ISBN-13 |
: 9264279962 |
Rating |
: 4/5 (64 Downloads) |
Synopsis Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations by : OECD
Author |
: Alan M. Rugman |
Publisher |
: |
Total Pages |
: 0 |
Release |
: 2017 |
ISBN-10 |
: 1315277557 |
ISBN-13 |
: 9781315277554 |
Rating |
: 4/5 (57 Downloads) |
Synopsis Multinationals and Transfer Pricing by : Alan M. Rugman
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 countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals' use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.
Author |
: OECD |
Publisher |
: OECD Publishing |
Total Pages |
: 247 |
Release |
: 2009-08-18 |
ISBN-10 |
: 9789264075344 |
ISBN-13 |
: 9264075348 |
Rating |
: 4/5 (44 Downloads) |
Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 by : OECD
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provides guidance on the valuation for tax purposes of cross-border transactions between associated enterprises.
Author |
: Wagdy M. Abdallah |
Publisher |
: Bloomsbury Publishing USA |
Total Pages |
: 272 |
Release |
: 2004-07-30 |
ISBN-10 |
: 9780313053689 |
ISBN-13 |
: 0313053685 |
Rating |
: 4/5 (89 Downloads) |
Synopsis Critical Concerns in Transfer Pricing and Practice by : Wagdy M. Abdallah
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 their tax laws and regulations, in efforts to close loopholes that have historically encouraged tax avoidance. In Critical Concerns in Transfer Pricing Policy and Practice, Wagdy Abdallah provides an in-depth overview of these recent trends and developments, and considers their implications for the management of MNCs. In particular, he discusses methods for pricing transferred goods and services in the e-commerce era and analyzes the most recent regulation reforms in such countries as Germany, Mexico, Japan, Canada, the United Kingdom, the United States, and the Netherlands. Anticipating increased scrutiny of MNC transfer pricing practices from governments and other external stakeholders, Abdallah outlines a set of practical recommendations for creating a successful transfer pricing system that maximizes value for the company while remaining sensitive to local policies in all of the countries in which it operates.