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…mehr
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.
Robert Feinschreiber (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. He has had numerous career highlights (e.g., member of the litigation team for the first Asian transfer pricing case (Toyota)). In addition, he is a consultant with the United Nations (Brazil, China, and Russia). Feinschreiber is on the editorial board of Wolters Kluwer - CCH, and Thomson - RIA. He has written over 25 books and is the co-editor of Corporate Business Taxation Monthly (CCH). He speaks at numerous conferences in the United States and Asia. Margaret Kent (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. She focuses on law and international taxation. She has been involved in a number of international transactions (i.e., structured the termination of the $2 billion per year aid from Russia to Cuba; structured transfer pricing in Latin America: Argentina, Chile, Colombia, Costa Rica, and Venezuela). Kent is also the co-editor of Corporate Business Taxation Monthly (CCH).
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PART I: BASIC TRANSFER PRICING STANDARDS 1 Chapter 1: Introduction 3 Chapter 2: Arm's Length Principle 7 Chapter 3: Arm's Length Range 19 Chapter 4: Safe Harbor Simplification 27 Chapter 5: Modifying Safe Harbor Simplification 47 Chapter 6: Global Formulary Apportionment 57 PART II: TRANSFER PRICING METHODOLOGIES 69 Chapter 7: Transactional Profit Split Measures 71 Chapter 8: Profit Split Illustrations 91 Chapter 9: Residual Profit Split Examples 99 Chapter 10: Transactional Net Margin Method 107 Chapter 11: Selecting Profit Indicators 133 Chapter 12: Selecting Transfer Pricing Methods 141 PART III: COMPARABILITY ANALYSIS 147 Chapter 13: How Comparability Analysis Works 149 Chapter 14: Comparability Techniques 177 Chapter 15: Timing and Comparability 205 PART IV: ADMINISTRATIVE APPROACHES 213 Chapter 16: Transfer Pricing Audits 215 Chapter 17: Monitoring the Guidelines 227 PART V: ADVANCED OECD ANALYSIS 239 Chapter 18: Documentation Requirements 241 Chapter 19: Intangible Property 247 Chapter 20: Service Arrangements 263 Chapter 21: Cost Contribution Arrangements 289 Chapter 22: Business Restructuring 315 PART VI: PUTTING THE GUIDELINES TO WORK 327 Chapter 23: Malaysia-Singapore Allocation Keys 329 Chapter 24: China-Taiwan Trade 345 Chapter 25: Reverse Engineering the Transfer Pricing Process 357 PART VII: CONNECTING TRANSFER PRICING AND PERMANENT ESTABLISHMENT 383 Chapter 26: Permanent Establishment Parameters 385 Chapter 27: Focus on Permanent Establishment 397 Index 417