Provide a straightforward and accessible introduction to this complex and increasingly important area of business taxation.
It offers readers an overall view of transfer pricing as it is practised today, including the 2017 changes to OECD transfer pricing guidance following the Base Erosion and Profit Shifting (BEPS) initiative. In addition to the theory of transfer pricing, this practical handbook explains how to implement transfer pricing models in global multinationals, how to monitor transactions to ensure compliance and how to create transfer pricing documentation.
This edition includes:
- The Nordic chapter covers a legislative summary of positions in Sweden, Norway, Finland, Iceland and Denmark
- Implementation of BEPS recommendations, including artificial avoidance or permanent establishment status and prevention of treaty abuse
- Implementation of transfer pricing documentation and country-by-country reporting
- Case law references
- Commentary on the OECD discussion draft on transfer pricing aspects of financial transactions, including treasury function, guarantee fees and captive insurance
- Coverage of Articles 7 and 9 of the OECD Model Tax Treaty
- Guidance on profit split and the recent trend towards the use of this transfer pricing methodology