TAXATION (INTERNATIONAL AND OTHER PROVISIONS) ACT 2010 TRANSFER PRICING GUIDELINES DESIGNATION... ORDER 2018 PDF Download

Author: GREAT BRITAIN.
Publisher:
ISBN: 9780111166567
Category :
Languages : en
Pages :

View

Book Description

Author: Great Britain
Publisher:
ISBN: 9780348240825
Category :
Languages : en
Pages : 0

View

Book Description
Enabling power: Taxation (International and Other Provisions) Act 2010, s. 164 (4) (b). Issued: 08.11.2022. Sifted: -. Made: 03.11.2022. Laid: 08.11.2022. Coming into force: 01.01.2023. Effect: SI. 2018/266 revoked. Territorial extent & classification: E/W/S/NI. General

Author: Robert Danon
Publisher: Kluwer Law International B.V.
ISBN: 9403540354
Category : Law
Languages : en
Pages : 1053

View

Book Description
It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.

Author: American Bar Association. House of Delegates
Publisher: American Bar Association
ISBN: 9781590318737
Category : Law
Languages : en
Pages : 216

View

Book Description
The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.

Author: Organisation for Economic Co-operation and Development
Publisher: OECD
ISBN:
Category : Business & Economics
Languages : en
Pages : 172

View

Book Description
A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.

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

View

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: 9264115609
Category :
Languages : en
Pages : 112

View

Book Description
This publication contains the official text of the Multilateral Convention on Mutual Assistance in Tax Matters as amended by the 2010 Protocol.

Author: United Nations
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 672

View

Book Description
The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.

Author: James K. Jackson
Publisher:
ISBN: 9781437927078
Category :
Languages : en
Pages : 21

View

Book Description
CFIUS is comprised of 9 members, two ex officio members, and other members as appointed by the Pres. representing major departments and agencies within the Exec. Branch. While the group generally has operated in relative obscurity, the proposed acquisition of commercial operations at six U.S. ports by Dubai Ports World in 2006 placed the group¿s operations under intense scrutiny. Contents of this report: Background; Establishment of CFIUS; The ¿Exon-Florio¿ Provision; Treasury Dept. Regulations; The ¿Byrd Amendment¿; The Amended CFIUS Process; Procedures; Factors for Consideration; Confidentiality Require.; Mitigation and Tracking; Congressional Oversight; CFIUS Since Exon-Florio; Impact of the Exon-Florio Process on CFIUS. Illus.

Author: United States. Department of Justice
Publisher: Createspace Independent Publishing Platform
ISBN: 9781503079229
Category : Barrier-free design
Languages : en
Pages : 0

View

Book Description
This revised title II regulation integrates the Department of Justice's new regulatory provisions with the text of the existing title II regulation that was unchanged by the 2010 revisions. Includes a section for guidance and analysis.