Now in its fourth edition, Global Transfer Pricing: Principles and Practices continues to 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 new edition includes: -An update on the 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 -Additional case law references Chapter updates include: -Chapter 5 'Financing' has been updated to include commentary on the OECD discussion draft on transfer pricing aspects of financial transactions, including treasury function, guarantee fees and captive insurance -Chapter 7 'Profit Split' has been expanded to cover new guidance on profit split and the recent trend towards the use of this transfer pricing methodology -The 'UK' chapter includes new content on interest restriction rules and transfer pricing, penalties for non-compliance, rules governing the conduct of transfer pricing audits and also Brexit considerations -A new chapter has been added on 'The Attribution of Profits to Permanent Establishments' to cover Articles 7 and 9 of the OECD Model Tax Treaty
Read an extract of Global Transfer Pricing: Principles and Practice
Table of Contents
Chapter 1 Transfer pricing: what is it? Chapter 2 OECD Chapter 3 Types of transaction: Tangible goods Chapter 4 Types of transaction: Intra-group services Chapter 5 Financing Chapter 6 Intangible property Chapter 7 Profit split Chapter 8 Business restructuring Chapter 9 Transfer pricing documentation Chapter 10 Operational transfer pricing Chapter 11 Tax audits and eliminating double taxation Chapter 12 UK transfer pricing legislation Chapter 13 The attribution of profits to permanent establishments Appendix A United Kingdom Transfer Pricing Summary