Transfer Pricing in a Post-BEPS World

Author: Michael Lang; Alfred Storck; Raffaele Petruzzi
Publisher: Kluwer Law International
ISBN: 9789041167101
Published In: September 2016
Format: Hardback , 240 pages
Jurisdiction: European Union ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

Details

The OECD’s Base Erosion and Profit Shifting (BEPS) project promises to make effective inroads into the much criticized corporate tax strategy known as aggressive transfer pricing, whereby the profitability of subsidiaries in different jurisdictions is “managed” via mispricing with the intent of minimizing the corporation’s overall tax burden. Although the OECD BEPS project is an ongoing endeavor, its accomplishments to date and developing trends are discernible. This book, including contributions by outstanding and renowned transfer pricing experts both from practice and academia, analyses these trends, and proposes reforms which would ensure that transfer pricing outcomes are better aligned with economic activities and value creation, which achieves a more equitable distribution of profits among different countries.

Each chapter is dedicated to specific sections of the OECD’s BEPS Action Plan. Among the topics and issues covered are the following:

arm’s length principle and its ongoing development;
allocation of risk and recharacterization;
intangibles (both license model and cost contribution arrangements);
interest deductions and intra-group financing;
low value-adding services;
commissionaire arrangements and low-risk distributors;
attribution of profits to permanent establishments;
documentation requirements (including Country-by-Country Reporting).

Within these topics, measures to identify the commercial and financial relationships inside multinational enterprises, to accurately delineate actual transactions, as well as guidance on defining risk and its allocation among entities of a multinational enterprise are discussed.

The book is based on papers presented and discussed at the first Global Transfer Pricing Conference hosted in February 2016 by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business).

The most up-to-date and thorough consideration of transfer pricing yet published, this book will prove invaluable for all parties currently facing questions related to transfer pricing in a post-BEPS world, especially those in charge of finding an ideal answer to them: academics, practitioners (including in-house and advisory counsel), international organizations, CEOs and CFOs of multinational enterprises, and government officials who are tax and transfer pricing experts.

Features

This book publicizes and examines the results of a transfer pricing research project, allowing new material and findings to be accessed by the general public for the first time.
It presents selected crucial topics and issues related to transfer pricing in a post-BEPS world, together with some possible solutions to these issues, by combining an academic and a practical approach.

Benefits

This book will prove to be useful for all parties currently facing questions related to transfer pricing topics in a post-BEPS world and those in charge of finding an ideal answer to them: academics, practitioners (including the business community and the advisory firms), international organizations, and government officials who are tax and transfer pricing experts, as well as CEOs and CFOs who are interested in this topic.

Preface

Editors

Contributors

Chapter 1 The Arm’s Length Principle: Between Legal Fiction and Economic Reality

Raffaele Petruzzi

Chapter 2 Risks Redefined in Transfer Pricing Post-BEPS

Sébastien Gonnet

Chapter 3 Transfer Pricing Aspects of Intangibles: The License Model

J. Scott Wilkie

Chapter 4 Transfer Pricing Aspects of Intangibles: The Cost Contribution Arrangement Model

Yariv Brauner

Chapter 5 Interest Deductions and Transfer Pricing Aspects of Intra-Group Financing