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Pris: 2332 SEK exkl. moms  |  Fundamentals of Transfer Pricing (Volume 1: Principles and Practice), the first of a three-volume series, is a book describing clearly and simply the key transfer pricing topics, with a collection of incisive and wide-ranging perspectives from representatives of academia, tax law practice, multinational companies, advisory groups, national tax authorities, and international organisations from all over the globe. Transfer pricing is a crucial and intricate subject in the realm of international taxation. Acknowledging its importance, most countries have enacted transfer pricing rules within their domestic tax frameworks.
What’s in this book:
The contributions collectively offer a comprehensive guide to the practical application of transfer pricing rules, covering the following various aspects:
- introduction to transfer pricing;
- accurate delineation and recognition of actual transactions;
- transfer pricing methods;
- comparability analysis;
- transfer pricing audits and litigation;
- administrative approaches to preventing and resolving transfer pricing disputes;
- transfer pricing documentation;
- attribution of profits to permanent establishments;
- transfer pricing and specific transactions;
- use of new technologies in transfer pricing; and
- interplay between transfer pricing and other rules.
Delving deep into both foundational concepts and emerging trends in transfer pricing, this book, featuring around 200 practical examples and over 200 case laws, provides readers with the tools to understand its dynamic application in real-world scenarios. By analysing examples, case studies, and the implications of recent judicial precedents, it bridges the gap between fundamental principles and practical implementations.
How this will help you:
The implementation of transfer pricing legislation remains one of the most challenging tasks for taxpayers and tax authorities globally. With this comprehensive source of pragmatic guidance, tax lawyers, in-house tax counsels, government officials, academics, advisory firms, and the business community around the world will have all the support they need to move forward in tackling this complex aspect of the current tax environment.
Table Of Contents
Editors
Assistant Editor
Contributors
List of Figures
List of Tables
List of Abbreviations
Preface
PART I
General Topics
CHAPTER 1
Introduction to Transfer Pricing
Raffaele Petruzzi, Giammarco Cottani, Stig Sollund & Sayee Prasanna
CHAPTER 2
Accurate Delineation and Recognition of Actual Transactions
Sayee Prasanna & Raffaele Petruzzi
CHAPTER 3
Transfer Pricing Methods: Traditional Transaction Methods
Melinda Brown & Marco Orlandi
CHAPTER 4
Transfer Pricing Methods: Transactional Profit Methods and Other Methods
Guillaume Madelpuech & Gabriela Capristano Cardoso
CHAPTER 5
Comparability Analysis
Sayee Prasanna
CHAPTER 6
Transfer Pricing Audits and Litigation
Andrew Hickman & Abhishek Padwalkar
CHAPTER 7
Administrative Approaches to Preventing Transfer Pricing Disputes
Marco Striato
CHAPTER 8
Administrative Approaches to Resolving Transfer Pricing Disputes
Pietro Piccone Ferrarotti & Eter Burkadze
CHAPTER 9
Transfer Pricing Documentation
Sven Breme
CHAPTER 10
Attribution of Profits to Permanent Establishments
Raphael Holzinger
PART II
Transactions
CHAPTER 11
Transfer Pricing and Services
Raffaele Petruzzi
CHAPTER 12
Transfer Pricing and Financial Transactions
Raffaele Petruzzi
CHAPTER 13
Transfer Pricing and Intangibles
Giammarco Cottani, Paolo Ludovici & Marco Striato
CHAPTER 14
Transfer Pricing and Business Restructurings
Sayee Prasanna
PART III
New Technologies
CHAPTER 15
Use of New Technologies in Transfer Pricing by Taxpayers
Eduardo Flöring
CHAPTER 16
Use of New Technologies in Transfer Pricing by Tax Authorities
Gonzalo Arias & Raul Zambrano
PART IV
Special Topics
CHAPTER 17
Transfer Pricing and Other Anti-abuse Rules
Mukesh Butani & Seema Kejriwal
CHAPTER 18
Transfer Pricing and Global Mobility
Ian Dykes & Sara Harris
CHAPTER 19
Transfer Pricing and Antitrust Rules
Marco D’Ostuni & Jacopo Figus Diaz
CHAPTER 20
Transfer Pricing and Customs Valuation
Karol Dziwinski
CHAPTER 21
Transfer Pricing and VAT
Pietro Bricchetto & Karol Dziwinski
CHAPTER 22
Transfer Pricing and Sustainability
Marcelo H.B. Moura
Table of Cases
Index | | |
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