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Fundamentals of Transfer Pricing, Volume 1: Principles and Practice

Fundamentals of Transfer Pricing, Volume 1: Principles and Practice

Author: Michael Lang; Giammarco Cottani; Raffaele Petruzzi
Publisher: Kluwer Law International
ISBN: 9789403543383
Published In: June 2025
Format: Hardback
Jurisdiction: Netherlands ? Disclaimer:
Countri(es) stated herein are used as reference only

List Price: HKD 1,870.41

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Description
Contents

Details

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.

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/Examinations 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 Bremer

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 R Flöring Jr.

CHAPTER 16. Use of New Technologies in Transfer Pricing by Tax Authorities

Raul Zambrano & Gonzalo Arias

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

Index

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