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Global Transfer Pricing: Principles and Practice, 5th Edition

Global Transfer Pricing: Principles and Practice, 5th Edition

Author: John Henshall; Deloitte Touche Tohmatsu
Publisher: Bloomsbury Professional (formerly Tottel Publishing)
ISBN: 9781526525024

Previous Edition ISBN: 9781526511218
Published In: November 2023
Format: Paperback , 228 pages
Jurisdiction: International ? Disclaimer:
Countri(es) stated herein are used as reference only

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Now in its fifth edition, Global Transfer Pricing: Principles and Practice continues to provide a straightforward and accessible introduction to this complex and increasingly important area of business taxation. It offers readers an overall view of transfer pricing as it is practised today. In addition to the theory of transfer pricing, this practical handbook explains how to implement transfer pricing models in global multinationals, how to monitor transactions to ensure compliance and how to create transfer pricing documentation. Readers will benefit from the practical experience that the Deloitte transfer pricing group have gained in helping businesses implement processes that deal with the business models that have evolved in today's increasingly competitive landscape. The transfer pricing environment has evolved significantly since the publication of the previous edition – changes reflected in this new edition include the impact of Brexit, Covid-19, guidance on financial transactions and IBOR and proposed updates to UK documentation requirements.

Roy Donegan is a partner in Deloitte's transfer pricing group, based in London, with 19 years' experience in the field. During that time, Roy has worked extensively on a wide range of transfer pricing matters, from advising on policies, through to documentation, implementation and liaising with tax authorities on tax payers behalf's. Within Deloitte, Roy leads a sub-group that focuses on advising privately owned groups on transfer pricing matters, ranging from large private companies and partnerships in the professional practices sector to innovative and entrepreneurial start-ups and fast-growing disruptor businesses

1. Transfer Pricing: What Is It?
2. OECD
3. Types of Transaction: Tangible Goods
4. Types of Transaction: Intra-group Services
5. Financing
6. Intangibles
7. Profit Split
8. Business Restructuring
9. Transfer Pricing Documentation
10. Operational Transfer Pricing
11. Tax Audits and Eliminating Double Taxation
12. UK Transfer Pricing Legislation
13. Allocation of Profits to Branches
Appendix A United Kingdom Transfer Pricing Summary
Appendix B International Quick Reference Guide

John Henshall has been a tax professional for 30 years at the time of writing this book. Training initially with the UK tax authority, he became a Partner at Deloitte in 2001. John is currently global co-lead of the Business Model Optimization service line and he has a particular interest in the transfer pricing of intangibles. Advising some of the largest multinationals, John’s work often leads to Advance Pricing Agreements, tax audit defence work or to Competent Authority claims. John has been consulted by governments concerning the modernization of their approach to international taxation. He has participated as a delegate to the November 2011 meeting of OECD Working Party 6, considering the update of Chapter VI of the OECD Guidelines for Multi-national Enterprises and Tax Administrations. John lectures extensively and he is regularly published.

Deloitte Touche Tohmatsu is one of the world’s largest providers of transfer-pricing services, with more than 500 transfer-pricing specialists around the world. Deloitte’s professional combine strong international tax and economic expertise with former tax authority experience; they work together in a global practice exclusively dedicated to transfer-pricing solutions and the resolution of transfer-pricing disputes. In addition to its strong international tax and economics base, Deloitte has extensive experience in Advance Pricing Agreement negotiations and Competent Authority claims.