Transfer pricing and value creation

Resource Information

The work Transfer pricing and value creation represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

Label

Transfer pricing and value creation

Contributor

• Petruzzi, R
• Tavares, R.J.S

Subject

• OECD Transfer Pricing Guidelines
• PE
• R&D
• anti-avoidance
• arm's length principle
• digital economy
• distribution centre
• immovable property
• manufacturing industry
• pharmaceutical industry
• services
• tax treaty
• telecommunication industry
• transactional profit methods
• transfer pricing
• value chain analysis
• value creation

Language

eng

Summary

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 analysing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. The book provides four parts: (1) introduction; (2) value creation and the application of the arm's length principle; (3) transfer pricing an global value chains; and (4) transfer pricing and value creation in specific industry sectors

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction

Series statement

• Series on International Tax Law
• Schriftenreihe zum Internationalen Steuerrecht

Series volume

• Vol. 116
• Band 116