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Fundamentals of Transfer Pricing: General Topics and Specific Transactions

Fundamentals of Transfer Pricing: General Topics and Specific Transactions

Author: Raffaele Petruzzi; Giammarco Cottani; Michael Lang
Publisher: Kluwer Law International
ISBN: 9789403517216
Published In: June 2021
Format: Hardback
Jurisdiction: International ? Disclaimer:
Countri(es) stated herein are used as reference only

List Price: HKD 1,649.19

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Description
Contents

Details

Fundamentals of Transfer Pricing is a crucially significant volume elucidating the practical application of transfer pricing rules considering all the most recent developments. In this compendium, stakeholders from governments, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives on general and specific topics. Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the past century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting triggered by the improper application of transfer pricing rules had resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. Thus, it is imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice.

What’s in this book:

With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation progresses from general to more specialised topics. The following aspects of the subject are thoroughly analysed:

what is transfer pricing and the purpose of transfer pricing rules;
the arm’s length principle and its application;
consequences of a transaction not being in accordance with the arm’s length principle;
transfer pricing methods;
mechanisms to avoid and resolve disputes;
transfer pricing documentation;
attribution of profits to permanent establishments;
transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings.

How this will help you:

The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will be abreast with the necessary detail for tackling this tricky aspect of the current tax environment.

Editors

Contributors

List of Figures

List of Tables

List of Abbreviations

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
Sebastien Gonnet & Guillaume Madelpuech & Gabriela Capristano Cardoso

CHAPTER 5
Comparability Analysis
Sayee Prasanna & Dorottya Kovács

CHAPTER 6
Administrative Approaches to Avoiding/Minimising TP Disputes
Svitlana Buriak & Marco Striato

CHAPTER 7
Administrative Approaches to Resolving Transfer Pricing Disputes
Pietro Piccone & Eter Burkadze

CHAPTER 8
Transfer Pricing Documentation
Sven Bremer

CHAPTER 9
Attribution of Profits to Permanent Establishments
Raphael Holzinger

CHAPTER 10
Transfer Pricing and Services
Raffaele Petruzzi

CHAPTER 11
Transfer Pricing and Intra-group Financial Transactions
Raffaele Petruzzi

CHAPTER 12
Transfer Pricing and Intangibles
Giammarco Cottani & Paolo Ludovici & Marco Striato

CHAPTER 13
Transfer Pricing and Business Restructurings
Sayee Prasanna & Zahira Quattrocchi

Index