Feinschreiber / Kent Transfer Pricing Handbook

Guidance for the OECD Regulations
1. Auflage 2012
ISBN: 978-1-118-37657-7
Verlag: John Wiley & Sons
Format: PDF
Kopierschutz: Adobe DRM (»Systemvoraussetzungen)

E-Book, Englisch, 448 Seiten, E-Book

Reihe: Wiley Corporate F&A

Learn OECD guidance on business taxation in multiplecountries
A business that is not aware of all of its exposure to the taxpolicy of each country in which it does business may find itselfpaying more in taxes that the share of profit it generates. TheOrganisation for Economic Co-operation and Development (OECD) seeksto reduce the risk of business taxation in multiple countries.Transfer Pricing Handbook explores how countries can applythe OECD Guidelines to tax businesses that conduct their endeavorsin more than one country. It is the ultimate comprehensive guidefor companies doing business globally.
* Helps companies properly price their goods and services forglobal markets
* Provides defenses for transfer pricing audits
* Provides standards for creating comparables thatmultijurisdictional tax administrations will accept
* Guides documentation requirements and timing issues
If you're doing business in more than one country, TransferPricing Handbook is a must-have, essential guide forsimplifying OECD regulations for your global company.

Autoren/Hrsg.

Feinschreiber, Robert

Kent, Margaret

Inhaltsverzeichnis

PART ONE: BASIC TRANSFER PRICING STANDARDS
Look at the basic OECD transfer pricing standards, beginning with the arm's length principle and the limits to this arm's length range concept. Examine the OECD's safe harbors simplification approaches and to its safe harbor modifications. Analyze the global formulary apportionment alternative.
Chapter 1: Introduction
Chapter 2: Arm's Length Principle
Chapter 3: Arm's Length Range
Chapter 4: Safe Harbor Simplification
Chapter 5: Modifying Safe Harbor Simplification
Chapter 6: Global Formulary Apportionment
PART TWO: TRANSFER PRICING METHODOLOGIES
Look at the OECD's transfer pricing methodologies, recognizing the importance of the transactional profit split alternative, the application of the residual profit split, and limitations on the transactional net margin method. Examine profit indicators and other transfer pricing ramifications.
Chapter 7: Transactional Profit Split Measures
Chapter 8: Profits Split Illustrations
Chapter 9: Residual Profit Split Examples
Chapter 10: Transactional Net Margin Method
Chapter 11: Selecting Profit Indicators
Chapter 12: Selecting Transfer Pricing Methods
PART THREE: COMPARABILITY ANALYSIS
Take a comprehensive look at comparability analysis, examining how the specifics of the comparability process and comparability analysis techniques, as well as the timing issues that arise in assessing comparability.
Chapter 13: How Comparability Analysis Works
Chapter 14: Comparability Techniques
Chapter 15: Timing and Comparability
PART FOUR: ADMINISTRATIVE APPROACHES
Examine the OECD's administrative approaches. Look to audits and advance pricing agreement techniques, and examine the monitoring process itself.
Chapter 16: Transfer Pricing Audits
Chapter 17: Monitoring the Guidelines
PART FIVE: ADVANCED OECD ANALYSIS
Gain insight into advanced OECD analysis. Examine the documentation requirements, intangible properties, and services arrangements. Analyze cost contribution arrangements and business restructuring.
Chapter 18: Documentation Requirements
Chapter 19: Intangible Property
Chapter 20: Services Arrangements
Chapter 21: Cost Contribution Arrangements
Chapter 22: Business Restructuring
PART SIX: PUTTING THE GUIDELINES TO WORK
Examine factual patterns we developed in Malaysia as compared to Singapore operations; and in Taiwan as compared to Chinese operations. Analyze techniques to reverse engineer the transfer pricing process.
Chapter 23: Malaysia-Singapore Allocation Keys
Chapter 24: China-Taiwan Trade
Chapter 25: Reverse Engineering the Transfer Pricing Process
PART SEVEN: CONNECTING TRANSFER PRICING AND PERMANENT ESTABLISHMENT
Connect transfer pricing with permanent establishment under the OECD provisions.
Chapter 26: Permanent Establishment Parameters
Chapter 27: Focus on Permanent Establishment
About the Authors 415
Index 417

Über Autor(innen)

Robert Feinschreiber (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. He has had numerous career highlights (e.g., member of the litigation team for the first Asian transfer pricing case (Toyota)). In addition, he is a consultant with the United Nations (Brazil, China, and Russia). Feinschreiber is on the editorial board of Wolters Kluwer - CCH, and Thomson - RIA. He has written over 25 books and is the co-editor of Corporate Business Taxation Monthly (CCH). He speaks at numerous conferences in the United States and Asia.
Margaret Kent (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. She focuses on law and international taxation. She has been involved in a number of international transactions (i.e., structured the termination of the $2 billion per year aid from Russia to Cuba; structured transfer pricing in Latin America: Argentina, Chile, Colombia, Costa Rica, and Venezuela). Kent is also the co-editor of Corporate Business Taxation Monthly (CCH).