Transfer Pricing And Dispute Resolution

Author : Anuschka Bakker
Publisher : IBFD
ISBN 13 : 9087221002
Total Pages : 807 pages
Book Rating : 4.03/5 ( download)

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Download or read book Transfer Pricing and Dispute Resolution written by Anuschka Bakker and published by IBFD. This book was released on 2011 with total page 807 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.

Author : Eduardo Baistrocchi
Publisher : Cambridge University Press
ISBN 13 : 1139916289
Total Pages : 975 pages
Book Rating : 4.88/5 ( download)

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Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2012-12-06 with total page 975 pages. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

Author : David Rosenbloom
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.40/5 ( download)

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Download or read book Transfer Pricing & Dispute Resolution written by David Rosenbloom and published by . This book was released on 2015 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Consists of the first three chapters of the 2011 edition which have been updated based on information available up to 15 September, 1 August, and 31 July 2014, respectively.

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264169466
Total Pages : 110 pages
Book Rating : 4.63/5 ( download)

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Download or read book Dealing Effectively with the Challenges of Transfer Pricing written by OECD and published by OECD Publishing. This book was released on 2012-01-18 with total page 110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report addresses the practical administration of transfer pricing programmes by tax administrations.

Author : Zvi Daniel Altman
Publisher : IBFD
ISBN 13 : 9076078947
Total Pages : 498 pages
Book Rating : 4.46/5 ( download)

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Download or read book Dispute Resolution Under Tax Treaties written by Zvi Daniel Altman and published by IBFD. This book was released on 2005 with total page 498 pages. Available in PDF, EPUB and Kindle. Book excerpt: As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers informing policies and in arguing positions, taking into account the subjective value given by each reader to each listed item. The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.

Author : Jana Kubicová
Publisher :
ISBN 13 : 9788075023230
Total Pages : pages
Book Rating : 4.34/5 ( download)

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Download or read book Transfer Pricing and Dispute Resolution Mechanism written by Jana Kubicová and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Author : S.K. Bilaney
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.97/5 ( download)

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Download or read book Transfer Pricing Litigation Trends and Dispute Resolution Mechanisms written by S.K. Bilaney and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is one of the most litigious areas of taxation. This article discusses transfer pricing litigation trends in India and various dispute resolution mechanisms available to taxpayers for resolving transfer pricing disputes. In addition, analyses of statistical data relating to results achieved by various dispute resolution mechanisms are also presented.

Author : M.R. Martin
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.05/5 ( download)

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Download or read book BEAT's Impact on Transfer Pricing Alternative Dispute Resolution written by M.R. Martin and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article discusses the new base erosion and anti-abuse tax (BEAT), which focuses on cross-border related party payments, bringing groups with international operations and transfer pricing arrangements into its sights. The authors examine the options for groups bound by now-unfavourable advance pricing agreements (APAs) with the U.S. and for other taxpayers subject to tax treaties with mutual agreement procedure (MAP) articles.

Author : Ghislain T. J. Joseph
Publisher :
ISBN 13 :
Total Pages : 31 pages
Book Rating : 4.36/5 ( download)

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Download or read book Transfer Pricing written by Ghislain T. J. Joseph and published by . This book was released on 2001 with total page 31 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Author :
Publisher :
ISBN 13 :
Total Pages : 32 pages
Book Rating : 4.61/5 ( download)

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Download or read book EU Joint Transfer Pricing Forum : Secretariat Discussion Paper on Alternative Dispute Avoidance and Resolution Procedures written by and published by . This book was released on 2005 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: This discussion paper suggests that EU members should consider a number of ways to settle cross-border transfer pricing disputes before they reach taxpayers, including consultations on audits and reassessments and establishing a model European advance pricing agreement to expedite bilateral APAs. It also suggests that member state tax authorities establish a model APA, thereby creating uniform EU APA requirements, consult one another before launching a transfer pricing audit, consider mutually agreed transfer pricing reassessments, and use mediation to hasten and streamline dispute resolution.