Tax Director's Guide to Transfer Pricing in Asia and Australia PDF Download

Author: Kenneth R. L. Parker
Publisher: Gbis, Incorporated
ISBN: 9781602310087
Category : Transfer pricing
Languages : en
Pages : 247

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Book Description
A dozen leading transfer pricing professionals from Baker & McKenzie, Deloitte, Ernst & Young, KPMG and PricewaterhouseCoopers offer their advice and insights on how to navigate complex issues in Australia, China, Hong Kong, India, Japan, and Singapore. Topics discussed include: application of safe harbor provisions in Australia, understanding Japan's new documentation requirements, strategies to minimize transfer pricing risk in India, implications of recent court decisions in Hong Kong, valuing intra-group services in Singapore, and how to apply the Best Method Rule in China. The book includes English translations of China and Japan's implementing regulations, and overview of the transfer pricing analysis process, and a glossary of transfer pricing terminology.

Author: J. Li
Publisher: Springer
ISBN: 0230511600
Category : Business & Economics
Languages : en
Pages : 296

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Book Description
In the management of business activity by companies operating in more than one country, the complex array of issues and practices that characterize their movements of assets between constituent company units centres around what has become known as international transfer payments. This book, based on extensive research, explains the nature of the subject, presents the latest data on the practice of transfer payments in three Asia Pacific countries; the regulations, attitudes and conditions which form the context in which they take place; and the events which are most likely to precipitate the intervention of the authorities and lead to investigation and audit.

Author: Brian E. Andreoli
Publisher: Gbis, Incorporated
ISBN: 9781602310049
Category : Business & Economics
Languages : en
Pages : 560

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Book Description
More than fifty of the world's leading transfer pricing professionals offer their advice and insights on how to navigate complex issues, including: When is an APA Advantageous?, Understanding the New U.S. Services Regulations, Transfer Pricing Implications of Reorganizations, Valuing Intangibles Under Cost Sharing Arrangements, and How to Apply the Best Method Rule. The book also provides a country-by-country review of transfer pricing laws in seventeen major economies, addressing questions such as: What transfer pricing methods are accepted?, Do the local tax authorities favor a given method?, What dispute resolution mechanisms are available?, Are APAs allowed and, if so, what are the rules, To what extent are international guidelines followed?, How is the acceptability of comparables determined?, What are the documentation requirements?, and How are non-compliance penalties calculated? This newly updated 2010 Edition builds on the success of the original Tax Director's Guide to International Transfer Pricing, which has been relied upon by international tax professionals around the world. The articles in this new edition reflect the intense competition for tax dollars among various countries in a time of global recession, during which many tightened their transfer pricing rules and increased enforcement. The majority of the articles contain significant substantive updates. In addition, the book includes five new country overview articles discussing transfer pricing rules and practices in Australia, Hong Kong, India, Japan, and Singapore. This edition also includes an entirely new China section in response to the major transfer pricing legislation that recently went into effect, as well as a new article on supply chain management. In-house tax specialists and outside advisors alike will find this book to be an invaluable resource in their efforts to manage global tax exposure.

Author: Robert Feinschreiber
Publisher: John Wiley & Sons
ISBN: 1118359402
Category : Business & Economics
Languages : en
Pages : 558

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Book Description
An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businesses A comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders. Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad. Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the law A complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad.

Author: Michael Lang
Publisher: Kluwer Law International B.V.
ISBN: 904119021X
Category : Law
Languages : en
Pages : 500

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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.

Author: Int. Management Forum (IMF)
Publisher: Int. Management Forum (IMF)
ISBN:
Category :
Languages : en
Pages : 25

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Book Description
How to deal with international Transfer Pricing risk? Transfer Pricing has drawn the attention of tax authorities worldwide. New rules, documentation requirements and different interpretation given to the OECD Transfer Pricing guidelines by both tax authorities and multinationals have created ground for many disputes. Major Transfer Pricing issues and concerns International Management Forum (IMF) is happy to announce a new distance learning course on Transfer Pricing. This Transfer Pricing course will focus on major Transfer Pricing issues and concerns that all professionals involved in the complex area of Transfer Pricing will face such as: Business Restructuring and Valuation, Transfer Pricing Legislation and Guidelines, Documentation Requirements per region and per country, Transfer Pricing Project and Risk management, Transfer Pricing (pre-) Controversy Management, Design and Development of a Transfer Pricing Policy, types of Intercompany Transactions, Intellectual Property and Customs. Target group of this Transfer Pricing course This new toplevel distance learning Transfer Pricing course has been designed to provide in depth training for financial, tax and Transfer Pricing professionals who are interested in expanding their knowledge of the theory and practice of Transfer Pricing. The course is relevant for Transfer Pricing managers, (inter)national tax managers and firms, finance directors, treasurers, senior executives with an interest in the latest developments in Transfer Pricing and lawyers and accountants who serve their clients with Transfer Pricing issues and have to guide them in the ever-changing Transfer Pricing environment. Note! Salary surveys among accountants, lawyers and economists reveil that practitioners with advanced Transfer Pricing knowlegde often earn more than twice as much as their counterparts with equivalent education and experience who lack Transfer Pricing expertise. Course materials The course consists of 11 lessons, each of which will require about 4 hours of self-study. Next to the lessons, you will also receive 'The Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations' by OECD. All course participants receive a Certificate of Participation.

Author: OECD
Publisher: OECD Publishing
ISBN: 9264265120
Category :
Languages : en
Pages : 612

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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: Brian E. Andreoli
Publisher: Gbis, Incorporated
ISBN: 9781602310018
Category : Business & Economics
Languages : en
Pages : 404

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Book Description
Forty-two of the world's leading transfer pricing professionals offer their advice and insights on how to navigate complex issues, and provide a country-by-country review of transfer pricing laws in a dozen major economies.

Author: Robert Feinschreiber
Publisher: John Wiley & Sons
ISBN: 0471651230
Category : Business & Economics
Languages : en
Pages : 338

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Book Description
Advanced praise for Transfer Pricing Methods "Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue." -Charles R. Goulding, Managing Director, Tax Cooper Industries, Inc. "It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses." -Vikram A. Gosain, JD, CPA, Director of Transfer Pricing General Electric Capital Corporation "This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants." -Joseph C. Mandarino, Partner Troutman Sanders, LLP "Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty." -Charles L. Crowley, Partner ITS/Customs and International Trade Practice, Ernst & Young, LLP "Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational." -Enrique MacGregor, Principal-in-Charge, Transfer Pricing Services Grant Thornton LLP "Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate." -Alan Getz, Vice President and General Manager, Tax Mitsui & Co., Inc. (U.S.A.) "Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner." -Per H. Hasenwinkle, National Practice Leader, Transfer Pricing BDO Seidman, LLP

Author: Robert Feinschreiber
Publisher: John Wiley & Sons
ISBN: 1118376560
Category : Business & Economics
Languages : en
Pages : 448

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Book Description
Learn OECD guidance on business taxation in multiple countries A business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying more in taxes that the share of profit it generates. The Organisation for Economic Co-operation and Development (OECD) seeks to reduce the risk of business taxation in multiple countries. Transfer Pricing Handbook explores how countries can apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. It is the ultimate comprehensive guide for companies doing business globally. Helps companies properly price their goods and services for global markets Provides defenses for transfer pricing audits Provides standards for creating comparables that multijurisdictional tax administrations will accept Guides documentation requirements and timing issues If you're doing business in more than one country, Transfer Pricing Handbook is a must-have, essential guide for simplifying OECD regulations for your global company.