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Author: Steven C. Wrappe Publisher: ISBN: Category : Languages : en Pages : 0
Book Description
As part of an increased openness to international investment and the resulting need to address international tax issues, the Kingdom of Saudi Arabia (KSA) recently adopted transfer pricing regulations consistent with global norms. Due to the newness of these regulations in the KSA tax system and the general difficulty of resolving transfer pricing disputes, the KSA continues to review the experience of other countries with transfer pricing rules, enforcement and disputes.This is the first of three papers that will examine the current and anticipated problems with the application of transfer pricing rules and explore potential methods to improve the transfer pricing dispute process in the KSA. This paper will explore the context and motivation for the adoption of transfer pricing rules by the KSA, the rules themselves, and the general enforcement approach. The second and third papers will focus on the experiences of the Internal Revenue Service (“IRS”) of the United States (“U.S.”) resolving and avoiding transfer pricing disputes and transfer pricing penalties and compliance incentives regarding transfer pricing documentation to see what procedures the KSA should consider adopting.
Author: Steven C. Wrappe Publisher: ISBN: Category : Languages : en Pages : 0
Book Description
As part of an increased openness to international investment and the resulting need to address international tax issues, the Kingdom of Saudi Arabia (KSA) recently adopted transfer pricing regulations consistent with global norms. Due to the newness of these regulations in the KSA tax system and the general difficulty of resolving transfer pricing disputes, the KSA continues to review the experience of other countries with transfer pricing rules, enforcement and disputes.This is the first of three papers that will examine the current and anticipated problems with the application of transfer pricing rules and explore potential methods to improve the transfer pricing dispute process in the KSA. This paper will explore the context and motivation for the adoption of transfer pricing rules by the KSA, the rules themselves, and the general enforcement approach. The second and third papers will focus on the experiences of the Internal Revenue Service (“IRS”) of the United States (“U.S.”) resolving and avoiding transfer pricing disputes and transfer pricing penalties and compliance incentives regarding transfer pricing documentation to see what procedures the KSA should consider adopting.
Author: Steven C. Wrappe Publisher: ISBN: Category : Languages : en Pages : 0
Book Description
We discuss the dispute resolution procedures employed by the U.S. Internal Revenue Service (IRS) to resolve and avoid transfer pricing disputes. The IRS has enforced transfer pricing rules for decades and its experience can act as a guide for the KSA to consider the procedures to manage transfer pricing disputes. In addition, the article would help foreign investors and companies understand the KSA's tax dispute environment, especially concerning transfer pricing, and procedures to resolve or avoid transfer pricing disputes in the KSA.
Author: Steven C. Wrappe Publisher: ISBN: Category : Languages : en Pages : 0
Book Description
In this Part 3, we explore the KSA's historic approach to penalties and the motivation to develop transfer pricing-specific penalties. For sake of illustration, we will review the IRS reasons for enactment of transfer pricing-specific penalties, the substance of those penalties, and the IRS experience applying those penalties. The IRS experience could inform the KSA's consideration whether to enact transfer pricing penalties and, if so, how those penalties should be structured.
Author: Eduardo Baistrocchi Publisher: Cambridge University Press ISBN: 1139916289 Category : Law Languages : en Pages : 975
Book Description
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: A. Abdul Raheem Publisher: ISBN: Category : Languages : en Pages :
Book Description
In anticipation of the introduction of a transfer pricing policy in Saudi Arabia, the General Authority of Zakat and Tax made an amendment in 2014 to article 10(11) of the Saudi tax by-laws, laying down the concept of the arm's length principle and including a provision to disallow any charges by a related party if in excess of arm's length value. This article provides a detailed description of the transfer pricing regulations in the Kingdom.
Author: B. Hassan Publisher: ISBN: Category : Languages : en Pages :
Book Description
On 30 May 2020, the Kingdom of Saudi Arabia (KSA) published updated transfer pricing (TP) guidelines to provide insight into the TP practice for taxpayers in the KSA, based on the application of the TP Bylaws. In this article, the author summarizes those TP guidelines with the objective to provide practical guidelines on the implementation of TP regulations in the KSA.
Author: OECD Publisher: OECD Publishing ISBN: 9264265120 Category : Languages : en Pages : 612
Book Description
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 ISBN: 9264921915 Category : Languages : en Pages : 658
Book Description
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: Steven C. Wrappe
Author: Steven C. Wrappe
Author: Steven C. Wrappe
Author: Steven C. Wrappe
Author: Eduardo Baistrocchi
Author: A. Abdul Raheem
Author: B. Hassan
Author: OECD
Author: Jana Kubicová
Author: S. Mahalingham
Author: OECD