Transfer Pricing in International Business
Publication Date: 2013-03-01
The increasing economic, social and political importance of trade in the modern era spawned a phenomenon called the multinational organization .These organizations, beginning with the Dutch East India Company, are capable of exercising extreme power not only in individual countries but globally. Countries, and often sub-national regions, compete vigorously against one another for the establishment of facilities for a multinational organization for they bring revenue, employment and economic activity. The only significant problem is that these organizations have a national home to where profits ultimately will have to come. In trying to bring the maximum amount of profit home, multinational organizations often engage in practices, particularly in relation to internal pricing, that frequently enrage either their host or home countries. These internal pricing activities, known more commonly as transfer pricing, have provoked reactions from national jurisdictions to monitor and modify the internal pricing activities of multinational organizations in ways that protect their revenue streams. This discord is so intense at times that it has caused managers to take their eye off the reason they are in business in the first place. Transfer pricing is not simply about maximizing revenue. It is a much more important management issue that treated unwisely or with ignorance, is likely to lead to an incongruity in the added value of products and services as well as the crucial return on capital employed. This book seeks to remind managers of those important issues and how easy it is to create friction between the interested parties if the pricing process is not properly thought out. It goes on to provide an insight into how such conflicts can be assuaged or avoided altogether and explains how transfer pricing may become a managerial tool by establishing a common language that may be used as one driver for creating added value throughout the organization.
Transfer Pricing Handbook
Publication Date: 2012-09-11
Learn OECD guidance on business taxation in multiple countries A business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying more in taxes that the share of profit it generates. The Organisation for Economic Co-operation and Development (OECD) seeks to reduce the risk of business taxation in multiple countries. Transfer Pricing Handbook explores how countries can apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. It is the ultimate comprehensive guide for companies doing business globally. Helps companies properly price their goods and services for global markets Provides defenses for transfer pricing audits Provides standards for creating comparables that multijurisdictional tax administrations will accept Guides documentation requirements and timing issues If you're doing business in more than one country, Transfer Pricing Handbook is a must-have, essential guide for simplifying OECD regulations for your global company.
Transfer Pricing in China
Publication Date: 2011-05-19
This Guide is a detailed overview of all aspects of transfer pricing in China. Produced in association with Transfer Pricing Associates, a specialist global transfer pricing firm, this is an essential work for any businessman trading with or conducting business in China. The book deals with all aspects of transfer pricing from a practical perspective, from designing and implementing a transfer pricing system, to managing China compliance and preparing for an audit.
Transfer Pricing Rules Compliance and Controversy (Third Edition)
Publication Date: 2009-07-01
Transfer pricing is one of the most significant tax issues for corporations having international operations. It attracts the scrutiny of tax authorities worldwide and continues to draw attention of more and more countries' tax legislatures. Because of the heavy impact of income allocations on the bottom line of a corporation's business, especially potentially forced ones, international tax and business professionals need to be very careful about their tax planning and compliance efforts in order to meet the established transfer pricing standards. Transfer Pricing: Rules, Compliance and Controversy offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Throughout the book, the authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures. (description from amazon.com)
Transfer Pricing and Corporate Taxation
Publication Date: 2008-10-14
National tax authorities individually determine multinational ?rms' country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors' returns are reduced accordingly. The FASB's Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries' interpretations thereof, the U. S.