Introduction to transfer pricing

Resource Information

The work Introduction to transfer pricing 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

Introduction to transfer pricing

Creator

• Introduction to transfer pricing
• Monsenego, J. (Jérôme)

Subject

• arm's length principle
• cross-border reorganization
• dispute resolution
• substance over form
• traditional transaction methods
• transactional profit methods
• transfer pricing
• allocation of profits

Language

eng

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

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction