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Global Transfer Pricing: Principles and Practice, 4th Edition

Global Transfer Pricing: Principles and Practice, 4th Edition

Author: John Henshall; Deloitte Touche Tohmatsu
Publisher: Bloomsbury Professional (formerly Tottel Publishing)
ISBN: 9781526511218

Previous Edition ISBN: 9781780439822
Published In: August 2019
Format: Paperback , 267 pages
Jurisdiction: International ? Disclaimer:
Countri(es) stated herein are used as reference only

New Edition is available now !

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.