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Resolving Transfer Pricing Disputes

2012-12-06 Law
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Release : 2012-12-06
Genre : Law
Kind : eBook
Book Rating : 289/5 ( reviews)

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Book Synopsis Resolving Transfer Pricing Disputes by : Eduardo Baistrocchi

Download or read book Resolving Transfer Pricing Disputes written by Eduardo Baistrocchi. This book was released on 2012-12-06. Available in PDF, EPUB and Kindle. Book excerpt: Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

Transfer Pricing and Dispute Resolution: Aligning Strategy and Execution

2011 Dispute resolution (Law)
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Release : 2011
Genre : Dispute resolution (Law)
Kind : eBook
Book Rating : 454/5 ( reviews)

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Book Synopsis Transfer Pricing and Dispute Resolution: Aligning Strategy and Execution by :

Download or read book Transfer Pricing and Dispute Resolution: Aligning Strategy and Execution written by . This book was released on 2011. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax disputes arise. In recent years, transfer pricing has become in financial terms the most important tax issue faced by multinational companies and tax authorities worldwide. In times of economic downturn, as experienced in recent years, when tax authorities are challenged for revenue, the handling of these issues requires great care, skill, creativity and a true awareness of the ramifications confronting each tax jurisdiction. This book sets out in detail not only the general laws in each tax jurisdiction impacted by the multinational companies' transfer pricing practices, but also the ancillary concerns of how the issue is interpreted locally as well as related to the OECD Guidelines; the varied approaches to administrative resolution of these issues, including specific alternative dispute resolution mechanisms and the effective uses of advance pricing agreements; correlative adjustment procedures in the event of transfer pricing adjustments; cross-border exchange of information concerns; and how to proceed to litigation if all else fails administratively. It is here that the book delves into the specific procedures for litigation in each country which must be evaluated as part of the overall strategy for controversy resolution. Unfortunately, today litigation is on the rise in numerous jurisdictions and the presumption of an administrative resolution is no longer correct. An additional feature of this book is how practical anecdotes are intertwined into the analysis to give the reader a sense of pragmatism for these issues. To this point, there are the various case studies which highlight the technicalities of the local rules, customs, and practices.

Transfer Pricing & Dispute Resolution

2015 Dispute resolution (Law)
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Author :
Release : 2015
Genre : Dispute resolution (Law)
Kind : eBook
Book Rating : /5 ( reviews)

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Book Synopsis Transfer Pricing & Dispute Resolution by : David Rosenbloom

Download or read book Transfer Pricing & Dispute Resolution written by David Rosenbloom. This book was released on 2015. Available in PDF, EPUB and Kindle. Book excerpt: Consists of the first three chapters of the 2011 edition which have been updated based on information available up to 15 September, 1 August, and 31 July 2014, respectively.

Transfer Pricing Litigation Trends and Dispute Resolution Mechanisms

2017
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Release : 2017
Genre :
Kind : eBook
Book Rating : /5 ( reviews)

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Book Synopsis Transfer Pricing Litigation Trends and Dispute Resolution Mechanisms by : S.K. Bilaney

Download or read book Transfer Pricing Litigation Trends and Dispute Resolution Mechanisms written by S.K. Bilaney. This book was released on 2017. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is one of the most litigious areas of taxation. This article discusses transfer pricing litigation trends in India and various dispute resolution mechanisms available to taxpayers for resolving transfer pricing disputes. In addition, analyses of statistical data relating to results achieved by various dispute resolution mechanisms are also presented.

Dealing Effectively with the Challenges of Transfer Pricing

2012-01-18
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Release : 2012-01-18
Genre :
Kind : eBook
Book Rating : 466/5 ( reviews)

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Book Synopsis Dealing Effectively with the Challenges of Transfer Pricing by : OECD

Download or read book Dealing Effectively with the Challenges of Transfer Pricing written by OECD. This book was released on 2012-01-18. Available in PDF, EPUB and Kindle. Book excerpt: This report addresses the practical administration of transfer pricing programmes by tax administrations.

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