Author: Paul D. BoyerPublisher: Elsevier
ISBN: 1483276961
Category : Science
Languages : en
Pages : 705
Book Description
Group Transfer Syntheses Coupled to ATP Cleavage
Group Transfer Syntheses Coupled to ATP Cleavage
Author: Paul D. BoyerPublisher: Elsevier
ISBN: 1483276961
Category : Science
Languages : en
Pages : 705
Book Description
Group Transfer Syntheses Coupled to ATP Cleavage
Transfer Pricing Aspects of Intra-Group Financing
Author: Raffaele PetruzziPublisher: Kluwer Law International B.V.
ISBN: 9041167331
Category : Law
Languages : en
Pages : 338
Book Description
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.
Transfer Pricing and Intra-group Financing
Author: Anuschka BakkerPublisher: IBFD
ISBN: 9087221525
Category : Business & Economics
Languages : en
Pages : 593
Book Description
This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
Fundamentals of Transfer Pricing
Author: Michael LangPublisher: Kluwer Law International B.V.
ISBN: 904119021X
Category : Law
Languages : en
Pages : 500
Book Description
Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.
Contributions to Education
Author: Columbia University. Teachers CollegePublisher:
ISBN:
Category : Education
Languages : en
Pages : 88
Book Description
A Study of Sex Behavior in the White Rat by Means of the Obstruction Method
Author: Arthur Thomas JersildPublisher:
ISBN:
Category : Association of ideas
Languages : en
Pages : 786
Book Description
Routine and Varying Practice as Preparation for Adjustment to a New Situation
Author: Leland Whitney CraftsPublisher:
ISBN:
Category : Complication experiments (Psychology)
Languages : en
Pages : 76
Book Description
Facilitation and Inhibition
Author: Thomas Nichols JenkinsPublisher:
ISBN:
Category : Psychophysiology
Languages : en
Pages : 488
Book Description
Directoplate Corporation V. Huebner-Bleistein Patents Company
Author: Cell Biology by the Numbers
Author: Ron MiloPublisher: Garland Science
ISBN: 1317230698
Category : Science
Languages : en
Pages : 400
Book Description
A Top 25 CHOICE 2016 Title, and recipient of the CHOICE Outstanding Academic Title (OAT) Award. How much energy is released in ATP hydrolysis? How many mRNAs are in a cell? How genetically similar are two random people? What is faster, transcription or translation?Cell Biology by the Numbers explores these questions and dozens of others provid