You have no items in your shopping cart.

Transfer Pricing and the Arm's Length Principle After BEPS

Transfer Pricing and the Arm's Length Principle After BEPS

  • Author:
  • Publisher: Oxford University Press
  • ISBN: 9780198802914
  • Published In: August 2017
  • Format: Hardback , 336 pages
  • Jurisdiction: International ? Disclaimer:
    Countri(es) stated herein are used as reference only

List Price: HKD 1,656.25

HKD 1,606.56 Save HKD 49.69 (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 
  • Author 
  • Details

    • The first book to provide a sustained analysis and critique of the transfer pricing rules based on the arm's length principle following the BEPS project
    • Provides an explanation of the development and evolution of the arm's length principle
    • Tackles key problem areas relating to complexity and avoidance, including the issue of "excessive capital" and risk
    • Extremely knowledgeable authors who have both been closely involved with the BEPS project

     

    This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS project, and describes the principal problems that had arisen with those rules. The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and the problems that remain after BEPS. It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic.

    This book is the most detailed and up-to-date publication on this highly topical and often controversial topic.

  • Introduction
    1: The Emergence of the ALP
    2: The Development of the ALP
    3: Practical Application of the Arm's Length Principle
    4: Practical and Theoretical Problems Encountered in Applying the Arm's Length Principle
    5: Capital
    6: BEPS Modifications to Transfer Pricing Rules
    7: Evaluation of BEPS Transfer Pricing Measures
    8: Prospects for the ALP After BEPS

  • Richard Collier, Centre for Business Taxation, Oxford, and Joseph L Andrus

    Richard Collier is an Associate Fellow at the Centre for Business Taxation in Oxford and is heavily involved in tax policy work. Previously he was a senior tax partner at PwC, specializing in financial sector tax and transfer pricing and permanent establishment issues. Richard is also a qualified barrister and chartered accountant and holds a Ph.D. in law.

    Joseph L Andrus was the Head of the Transfer Pricing Unit at the OECD until his retirement in 2014. He was responsible for directing all of the OECD work in transfer pricing including the transfer pricing portions of the OECD project on corporate Base Erosion and Profit Shifting. He is also a member of the United Nations Subcommittee on Transfer Pricing. Prior to joining the OECD, Joseph had 35 years of experience as an advisor on transfer pricing matters. He was a transfer pricing partner at PwC and at Baker & McKenzie, and served in the mid-1980s as Deputy International Tax Counsel at the US Treasury Department He is an attorney and holds a J.D. degree from the University of Chicago Law School.

You may also be interested in these books:

Drafting Employment Documents for Expatriates, 2nd Edition
Drafting Employment Documents for Expatriates, 2nd Edition

List Price: HKD 1,350.00

HKD 1,309.50 Save HKD 40.50 (3%)

How to Lead a Values-Based Professional Services Firm: 3 Keys to Unlock Purpose and Profit
How to Lead a Values-Based Professional Services Firm: 3 Keys to Unlock Purpose and Profit

List Price: HKD 400.00

HKD 388.00 Save HKD 12.00 (3%)

Butterworths Hong Kong Employee Compensation Handbook, 6th Edition
Butterworths Hong Kong Employee Compensation Handbook, 6th Edition

List Price: HKD 1,900.00

HKD 1,843.00 Save HKD 57.00 (3%)

Butterworths Hong Kong Employment Law Handbook, 6th Edition
Butterworths Hong Kong Employment Law Handbook, 6th Edition

List Price: HKD 2,100.00

HKD 2,037.00 Save HKD 63.00 (3%)

Workplace Investigations, 2nd Edition
Workplace Investigations, 2nd Edition

List Price: HKD 680.00

HKD 659.60 Save HKD 20.40 (3%)

Armstrong's Handbook of Human Resource Management Practice, 14th Edition
Armstrong's Handbook of Human Resource Management Practice, 14th Edition

List Price: HKD 607.50

HKD 589.28 Save HKD 18.22 (3%)

Individual Income Tax Planning for Expatriates in China, 6th Edition
Individual Income Tax Planning for Expatriates in China, 6th Edition

List Price: HKD 1,280.00

HKD 1,241.60 Save HKD 38.40 (3%)

Hong Kong Employment Law: A Practical Guide, 5th Edition
Hong Kong Employment Law: A Practical Guide, 5th Edition

List Price: HKD 1,500.00

HKD 1,455.00 Save HKD 45.00 (3%)

The Employee Experience: How to Attract Talent, Retain Top Performers, and Drive Results
The Employee Experience: How to Attract Talent, Retain Top Performers, and Drive Results

List Price: HKD 280.00

HKD 271.60 Save HKD 8.40 (3%)

Butterworths Employment Law Handbook 2020
Butterworths Employment Law Handbook 2020

List Price: HKD 2,604.00

HKD 2,525.88 Save HKD 78.12 (3%)

Employment Law in China, 4th Edition
Employment Law in China, 4th Edition

List Price: HKD 800.00

HKD 400.00 Save HKD 400.00 (50%)

Hiring Greatness: How to Recruit Your Dream Team and Crush the Competition
Hiring Greatness: How to Recruit Your Dream Team and Crush the Competition

List Price: HKD 270.00

HKD 261.90 Save HKD 8.10 (3%)

Employees' Intellectual Property Rights, 2nd Edition
Employees' Intellectual Property Rights, 2nd Edition

List Price: HKD 1,850.00

HKD 1,794.50 Save HKD 55.50 (3%)

Employment Law and Practice in Hong Kong, 2nd Edition
Employment Law and Practice in Hong Kong, 2nd Edition

List Price: HKD 4,701.00

HKD 4,559.97 Save HKD 141.03 (3%)

International Employment Law Disputes
International Employment Law Disputes

List Price: HKD 1,980.00

HKD 1,920.60 Save HKD 59.40 (3%)

Settlement of Individual Employment Disputes
Settlement of Individual Employment Disputes

List Price: HKD 1,687.50

HKD 1,636.88 Save HKD 50.62 (3%)

Developing Human Capital
Developing Human Capital

List Price: HKD 600.00

HKD 582.00 Save HKD 18.00 (3%)

Managing Employment Relations, 7th Edition
Managing Employment Relations, 7th Edition

List Price: HKD 648.00

HKD 628.56 Save HKD 19.44 (3%)

Performance Management
Performance Management

List Price: HKD 337.50

HKD 150.00 Save HKD 187.50 (56%)

Simply HR
Simply HR

List Price: HKD 320.00

HKD 35.00 Save HKD 285.00 (89%)