Tax Transfer Pricing
Under the Arm's Length and the Sale Country Principles
- 446 pages
- English
- ePUB (mobile friendly)
- Available on iOS & Android
About this book
The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm's length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry.A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application, how they were decided if litigation truly occurred, and finally the author's motivated opinion with special focus on which is "the breaking point" of a specific analysis. The term "breaking point" is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution.Extract from the preface of prof. Reuven Avi-Yonah: "this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers".
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Information
Table of contents
- Index of examples
- Preface
- Introduction
- Chapter 1 - Economics of transfer pricing; contract theory and the arm’s length principle (ALP)
- Chapter 2 - History and purpose (ratio legis) of transfer pricing rules
- Chapter 3 - The arm’s length principle (ALP): key concepts and possible alternatives
- Chapter 4 - Legal guidance on applying the arm’s length principle (ALP)
- Chapter 5 - Legal methods to comply with the arm’s length principle (ALP)
- Chapter 6 - Intangibles, services, cost sharing, and (a summary of) financial transactions1
- Chapter 7 - Economic rationale of the arm’s length principle (ALP): a theory of extra profit (or losses) arising from innovation
- Chapter 8 - The arm’s length principle (ALP) in practice for tangible property and services1
- Chapter 9 - The arm’s length principle (ALP) in practice for intangible properties and cost sharing
- Chapter 10 - Largest and Giant Multinationals: taxation of a share of global extra profits in the country of sale and the minimum tax (a primer)
- Chapter 11 - Audit power of tax authorities and administrative compliance aspects for companies (outline)
- Chapter 12 - Actual and current issues in international tax transfer pricing1
- Analytical index of topics
- Bibliography