Coverart for item
The Resource Transactional adjustments in transfer pricing

Transactional adjustments in transfer pricing

Label
Transactional adjustments in transfer pricing
Title
Transactional adjustments in transfer pricing
Creator
Subject
Language
eng
Summary
This book examines whether, and to what extent, transactional adjustments may be applied within transfer pricing, i.e. whether it is possible to alter conditions and circumstances (other than prices or margins) of transactions conducted between related parties. In the context of the comparability analysis demanded by transfer pricing rules, the conditions and circumstances of controlled transactions normally serve to define the magnitude of its identity with an uncontrolled comparable reference, to determine if primary adjustments on profits need to be implemented. Nevertheless, it is relevant to question whether these very factors could also be subject to adjustments, since altering the features of controlled transactions, such as the attribution of risks, the re-allocation of intangible assets or even the entire disregarding of a loan transaction, will undoubtedly have an impact on the profits of the assessed entity. In this book, it is shown that transactional adjustments are not only possible but also inherent to the arm's length principle. However, a clear and precise delineation of stringent boundaries, both in the scope and the manner in which adjustments are to be applied, is essential to mitigate undue discretion. Through the examination of such limits, defined in accordance with the arm's length principle, a model on the enforcement of transactional adjustments is proposed. This model is of interest not only for determining the proper implementation of the referred adjustments, but also to duly assess the appropriateness of their treatment in different frameworks, ranging from parameters defined in the OECD Transfer Pricing Guidelines and base erosion and profit shifting (BEPS) actions referring to transfer pricing, to domestic transfer pricing rules and court decisions. Furthermore, the impact of transactional adjustments on specific scenarios that practitioners, tax administrations and courts have to face regularly within the realm of transfer pricing is thoroughly examined - namely, on the distribution of risks, the attribution of profits generated by intangible assets, the assessment of hard-to-value intangibles, business restructurings and cost sharing agreements
http://library.link/vocab/creatorName
Navarro Ibarrola, A
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
IBFD Doctoral Series
Series volume
40
http://library.link/vocab/subjectName
  • transfer pricing
  • transfer pricing adjustment
  • comparability analysis
  • arm's length principle
  • risk
  • intangibles
  • hard-to-value intangibles
  • reorganization
  • cost sharing arrangement
Label
Transactional adjustments in transfer pricing
Instantiates
Publication
Extent
xxx, 350 p.
Isbn
9789087224356
Isbn Type
(print)
Issn
1570-7164
Label
Transactional adjustments in transfer pricing
Publication
Extent
xxx, 350 p.
Isbn
9789087224356
Isbn Type
(print)
Issn
1570-7164

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
    • IBFD Library Kuala LumpurBorrow it
      No. 1 The Boulevard, Mid Valley City Suite 22.03, Level 22, Centrepoint South Lingkaran Syed Putra, Kuala Lumpur, 59200, MY
      3.148008 101.712199
Processing Feedback ...