Introduction to transfer pricing

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Summary: This book provides a general introduction to the fundamentals of transfer pricing. The book is focused on explanations of the principles that apply, albeit to various extents, in most countries. Although the majority of these principles is provided by the OECD, the views of other international organizations, in particular the United Nations and the European Union, are also taken into account. Moreover, the book illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when conducting cross-border business activities. Such examples are intended to facilitate the understanding of transfer pricing principles, and emphasize the tax planning or risk mitigating aspects that may be considered by multinational enterprises and that need to be monitored by tax administrations. Also included are relevant court cases from a variety of countries. Among the issues and topics covered are the following: the arm's length principle in theory and practice; transfer pricing methods recognized by the OECD Guidelines; intercompany transactions involving intangibles; common types of intercompany transactions and transfer pricing models; cross-border business restructurings; the substance requirement for transfer pricing purposes; attribution of profits to permanent establishments; and the prevention and resolution of transfer pricing disputes

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Summary: This book provides a general introduction to the fundamentals of transfer pricing. The book is focused on explanations of the principles that apply, albeit to various extents, in most countries. Although the majority of these principles is provided by the OECD, the views of other international organizations, in particular the United Nations and the European Union, are also taken into account. Moreover, the book illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when conducting cross-border business activities. Such examples are intended to facilitate the understanding of transfer pricing principles, and emphasize the tax planning or risk mitigating aspects that may be considered by multinational enterprises and that need to be monitored by tax administrations. Also included are relevant court cases from a variety of countries. Among the issues and topics covered are the following: the arm's length principle in theory and practice; transfer pricing methods recognized by the OECD Guidelines; intercompany transactions involving intangibles; common types of intercompany transactions and transfer pricing models; cross-border business restructurings; the substance requirement for transfer pricing purposes; attribution of profits to permanent establishments; and the prevention and resolution of transfer pricing disputes

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