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Global Transfer Pricing: Principles and Practice, 4th Edition

Global Transfer Pricing: Principles and Practice, 4th Edition

  • Author:
  • Publisher: Bloomsbury Professional (formerly Tottel Publishing)
  • ISBN: 9781526511218
  • Published In: August 2019
  • Format: Paperback , 267 pages
  • Jurisdiction: International ? Disclaimer:
    Countri(es) stated herein are used as reference only

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  • Description 
  • Contents 
  • Author 
  • Details

    The previous edition was published shortly after the end of the OECD BEPS recommendation phase had finished and we are now well into the implementation phase, with much follow-up work having been done on the original Actions. Therefore this new edition will include:-

    • an update on implementation of BEPS recommendations, including artificial avoidance of permanent establishment status and prevention of treaty abuse
    • implementation of transfer pricing documentation and country-by-country reporting
    • multilateral instrument implementation. In particular:
    • Chapter 5 'Types of Transaction: Financing' will be updated to include commentary on the OECD discussion draft on transfer pricing aspects of financial transactions, including treasury function, guarantee fees and captive insurance
    • Chapter 7 will be expanded to cover new guidance on profit split and the recent trend towards profit split in HMRC enquiries
    • The 'UK' chapter will include new content on interest restriction rules and transfer pricing, penalties for non-compliance, rules governing the conduct of transfer pricing audits and also Brexit considerations
    • A new chapter will be added on the 'Allocation of profits to branches' to cover Articles 7 and 9 and work with Financial Services teams on Financial Services branches.

    Legislation and case law:

    • OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017)
    • Individual OECD BEPS Reports detailing revised guidance on the BEPS Action Plan, including the OECD/G20 Inclusive Framework on BEPS: Progress Report (July 2018)
  • Chapter 1 Transfer pricing: what is it? 
    Chapter 2 OECD 
    Chapter 3 Types of transaction: Tangible goods 
    Chapter 4 Types of transaction: Intra-group services 
    Chapter 5 Financing 
    Chapter 6 Intangible property 
    Chapter 7 Profit split 
    Chapter 8 Business restructuring 
    Chapter 9 Transfer-pricing documentation 
    Chapter 10 Operational transfer pricing 
    Chapter 11 Tax audits and eliminating double taxation 
    Chapter 12 UK transfer-pricing legislation 
    Appendix A United Kingdom Transfer Pricing Summary 
    Appendix B International Quick Reference Guide 2016

  • 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.

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