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Author : Hubertus Bernardus Antonius Steens
Release : 2008
Genre :
Kind : eBook
Book Rating : /5 ( reviews)
Book Synopsis Impacts of Transfer Pricing on Value Creation by : Hubertus Bernardus Antonius Steens
Download or read book Impacts of Transfer Pricing on Value Creation written by Hubertus Bernardus Antonius Steens. This book was released on 2008. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Raffaele Petruzzi
Release : 2019-09-02
Genre : Law
Kind : eBook
Book Rating : 38X/5 ( reviews)
Book Synopsis Transfer Pricing and Value Creation by : Raffaele Petruzzi
Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi. This book was released on 2019-09-02. Available in PDF, EPUB and Kindle. Book excerpt: Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Author : Raffaele Petruzzi
Release : 2019
Genre :
Kind : eBook
Book Rating : 232/5 ( reviews)
Book Synopsis Transfer Pricing and Value Creation by : Raffaele Petruzzi
Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi. This book was released on 2019. Available in PDF, EPUB and Kindle. Book excerpt:
Author : OECD
Release : 2015-10-19
Genre :
Kind : eBook
Book Rating : 237/5 ( reviews)
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports written by OECD. This book was released on 2015-10-19. Available in PDF, EPUB and Kindle. Book excerpt: The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
Author : Brigitte Baumgartner
Release : 2018
Genre :
Kind : eBook
Book Rating : /5 ( reviews)
Book Synopsis Value Creation Analysis for Transfer Pricing Purposes by : Brigitte Baumgartner
Download or read book Value Creation Analysis for Transfer Pricing Purposes written by Brigitte Baumgartner. This book was released on 2018. Available in PDF, EPUB and Kindle. Book excerpt: The author presents a practical and pragmatic option to perform value creation analysis for transfer pricing purposes. Following Michael Porter's concepts, this article addresses five steps that can help the reader understand and follow an economic analysis to align a transfer pricing policy with a company strategy.
