You have no items in your shopping cart.

Transfer Pricing and Financing

Transfer Pricing and Financing

  • Author:
  • Publisher: Kluwer Law International
  • ISBN: 9789403540221
  • Published In: March 2023
  • Format: Hardback
  • Jurisdiction: International ? Disclaimer:
    Countri(es) stated herein are used as reference only

List Price: HKD 1,330.00

HKD 1,290.10 Save HKD 39.90 (3%)

Delivery Time: around 3-4 weeks
Extra 2-10 working days if shipping address outside Hong Kong
Free delivery Hong Kong?
Hong Kong: free delivery (order over HKD 1000)
OR
  • Description 
  • Contents 
  • Details

    In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties.

     

    Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions:

    •  loans;
    • financial guarantees;
    • cash pooling;
    • hybrid financing;
    • factoring;
    • captive insurance; and
    • asset management.

     

    Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law.

     

    Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.

  • Editors

    Contributors

    Preface

    CHAPTER 1

    Introduction

    CHAPTER 2

    Transfer pricing aspects of loans

    Antonio Russo, Andre Dekker & Tim Böhne

    CHAPTER 3

    Transfer Pricing Aspects of Financial Guarantees

    Andrew Hickman and Marcelo H. B. Moura

    CHAPTER 4

    Cash Pooling

    CHAPTER 5

    Hybrid Financing

    CHAPTER 6

    Transfer Pricing Aspects of Factoring

    CHAPTER 7

    Transfer Pricing Principles for Captive Insurance

    Stanley J Hales & and Lucie Hovorkova

    CHAPTER 8

    Transfer Pricing Aspects of Asset Management

    Dr. Georg Dettmann

    Table of Cases

    Index

You may also be interested in these books:

Hong Kong Company Secretary Checklist, 2nd Edition
Hong Kong Company Secretary Checklist, 2nd Edition

List Price: HKD 1,380.00

HKD 1,338.60 Save HKD 41.40 (3%)

The Hong Kong Company Secretary's Handbook: Practice and Procedure (11th Edition)
The Hong Kong Company Secretary's Handbook: Practice and Procedure (11th Edition)

List Price: HKD 535.00

HKD 518.95 Save HKD 16.05 (3%)

Hong Kong Tax & Accounting Practical Toolkit (Basic Package)
Hong Kong Tax & Accounting Practical Toolkit (Basic Package)
HKD 3,300.00
Butterworths Hong Kong Immigration Law Handbook, 4th Edition
Butterworths Hong Kong Immigration Law Handbook, 4th Edition

List Price: HKD 1,400.00

HKD 1,358.00 Save HKD 42.00 (3%)

Hong Kong Conveyancing Law, 9th Edition
Hong Kong Conveyancing Law, 9th Edition

List Price: HKD 2,000.00

HKD 1,940.00 Save HKD 60.00 (3%)

Company Law in Hong Kong: Practice and Procedure 2023 (Hardcopy + e-Book)
Company Law in Hong Kong: Practice and Procedure 2023 (Hardcopy + e-Book)

List Price: HKD 3,198.00

HKD 3,102.06 Save HKD 95.94 (3%)

Company Law in Hong Kong: Insolvency 2023 (Hardcopy + e-Book)
Company Law in Hong Kong: Insolvency 2023 (Hardcopy + e-Book)

List Price: HKD 2,843.00

HKD 2,757.71 Save HKD 85.29 (3%)

Law of Companies in Hong Kong, 4th Edition (Hardcopy + e-Book)
Law of Companies in Hong Kong, 4th Edition (Hardcopy + e-Book)

List Price: HKD 3,500.00

HKD 3,395.00 Save HKD 105.00 (3%)

Private Equity in Hong Kong and China, 4th Edition
Private Equity in Hong Kong and China, 4th Edition

List Price: HKD 2,000.00

HKD 1,940.00 Save HKD 60.00 (3%)

Butterworths Hong Kong Company Law Handbook, 25th Edition
Butterworths Hong Kong Company Law Handbook, 25th Edition

List Price: HKD 4,500.00

HKD 4,365.00 Save HKD 135.00 (3%)

Hong Kong Family Court Practice, 4th Edition
Hong Kong Family Court Practice, 4th Edition

List Price: HKD 2,700.00

HKD 2,619.00 Save HKD 81.00 (3%)

Brooke's Notary Hong Kong, 3rd Edition
Brooke's Notary Hong Kong, 3rd Edition

List Price: HKD 1,700.00

HKD 1,649.00 Save HKD 51.00 (3%)

Butterworths Hong Kong Employees' Compensation Handbook, 7th Edition
Butterworths Hong Kong Employees' Compensation Handbook, 7th Edition

List Price: HKD 2,100.00

HKD 2,037.00 Save HKD 63.00 (3%)

Chitty On Contracts: Hong Kong Specific Contracts (7th Edition) (Hardcopy + e-Book)
Chitty On Contracts: Hong Kong Specific Contracts (7th Edition) (Hardcopy + e-Book)

List Price: HKD 8,995.00

HKD 8,725.15 Save HKD 269.85 (3%)

Hong Kong Company Secretary Checklist
Hong Kong Company Secretary Checklist

List Price: HKD 1,380.00

HKD 1,338.60 Save HKD 41.40 (3%)

Butterworths Hong Kong Securities Law Handbook, 7th Edition
Butterworths Hong Kong Securities Law Handbook, 7th Edition

List Price: HKD 3,700.00

HKD 3,589.00 Save HKD 111.00 (3%)

Butterworths Hong Kong Employment Law Handbook, 7th Edition
Butterworths Hong Kong Employment Law Handbook, 7th Edition

List Price: HKD 2,300.00

HKD 2,231.00 Save HKD 69.00 (3%)

Cross-Border Mergers and Acquisitions and Financing, 4th Edition
Cross-Border Mergers and Acquisitions and Financing, 4th Edition

List Price: HKD 1,800.00

HKD 1,746.00 Save HKD 54.00 (3%)

Butterworths Hong Kong Company Law (Winding-Up and Miscellaneous Provisions) Handbook, 5th Edition
Butterworths Hong Kong Company Law (Winding-Up and Miscellaneous Provisions) Handbook, 5th Edition

List Price: HKD 2,000.00

HKD 1,940.00 Save HKD 60.00 (3%)

Hong Kong Basic Law Handbook, 3rd Edition
Hong Kong Basic Law Handbook, 3rd Edition

List Price: HKD 2,000.00

HKD 1,940.00 Save HKD 60.00 (3%)