Transfer Pricing and Tax Avoidance: A Global Guide From Practical Law, 2nd Edition

Author: David Chodikoff
Publisher: Sweet & Maxwell U.K.
ISBN: 9780414062856

Previous Edition ISBN: 9780414033504
Published In: June 2017
Format: Hardback , 669 pages
Jurisdiction: International ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents
Author

Details

Transfer Pricing & Tax Avoidance: Jurisdictional Comparisons is the essential reference guide for corporations, financial institutions and legal professionals. Covering major jurisdictions worldwide it provides a clear overview of the law relating to transfer pricing and tax avoidance in each one, and is structured to allow easy comparisons between jurisdictions.

Offers a well organised starting point for international reference
Covers the law in major jurisdictions around the world
Uses a reader-friendly Q&A format that enables quick and easy crossjurisdictional comparisons
Includes contributions from leading local practitioners who are experts in the field
Addresses the key questions of multinational organisations
Transfer pricing: covers topics such as legislative framework; national policy initiatives; revenue authority initiatives; administrative guidelines; case law; penalties; dispute resolution mechanisms
Tax avoidance: covers topics such as acceptable tax planning areas; definitions of abusive tax avoidance; legislative framework; key case law; penalties; current trends
Provides straightforward, practical commentary on each jurisdiction and the respective legal systems

Part One: Transfer Pricing

1.1 General Overview

1.2 Identification of Legislative Framework

1.2.1 Federal Legislation

1.2.2 State and Provincial Legislative Interplay

1.2.3 International Treaties and Agreements

2.1 National Policy Issues

2.1.1 Overall National Policy Announcements

2.1.2 National Revenue Authority Initiatives

2.1.3 Administrative Statements

2.1.4 Administrative Guidelines

3.1 Case Law

3.1.2 Current Cases

3.1.3 Historical Cases of Note

4.1 Penalties

4.1.2 Types

4.1.3 Special or Notable Cases

5.1 Dispute Resolution Mechanisms

5.1.2 Preferred National Options

5.1.3 International Choices

Part Two: Tax Avoidance

6.1 Acceptable Tax Planning Areas / Subjects

7.1 Defining Abusive Tax Avoidance (National Considerations)

8.1 The Legislative Framework

9.1 Key Cases of Interest

9.1.1 Current Cases

9.1.2 Key Historical Cases

10. Penalties
10.1 Legislative Provisions
10.1.2 Examples of Penalties Imposed

11 Current Trends
11.1 National Policy and Law
11.1.2 The Impact and Role of the OECD and Other International Relations

GENERAL EDITOR

David W. Chodikoff specializes in Tax Litigation (Civil and Criminal) and International Tax Dispute Resolution. He represents clients in tax disputes with government tax authorities before the courts.

THE FIRM

Miller Thomson enjoys a reputation as one of Canada’s most respected national business law firms. Through strategic growth, Miller Thomson has added enhanced capabilities, depth and resources in many core and specialty areas of expertise.