Global Transfer Pricing: Principles and Practice

Global Transfer Pricing: Principles and Practice cover

Description

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

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

Product details

Published 25 Jul 2019
Format Paperback
Edition 4th
Extent 312
ISBN 9781526511218
Imprint Bloomsbury Professional
Dimensions 234 x 156 mm
Publisher Bloomsbury Publishing

About the contributors

Author

John Henshall

John Henshall has 30 years’ experience in internat…

Author

Roy Donegan

Roy Donegan has been a tax professional with Deloi…