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Now in its sixth edition,
Global Transfer Pricing: Principles and Practice continues to provide a straightforward and accessible introduction to this complex and increasingly important area of business taxation.
It offers readers an overall view of transfer pricing as it is practised today. In addition to the theory of transfer pricing, this practical handbook explains how to implement transfer pricing models in global multinationals, how to monitor transactions to ensure compliance and how to create transfer pricing documentation. Readers will benefit from the practical experience that the Deloitte transfer pricing group have gained in helping businesses implement processes that deal with the business models that have evolved in today's increasingly competitive landscape.
The transfer pricing environment has evolved significantly since the publication of the previous edition:
- New 'Amount B' simplified guidance on wholesale tangible goods guidance issued by the OECD;
- New EU public Country-by-Country Reporting rules;
- Links between Country-by-Country Reporting and Pillar 2 thresholds (and exemptions); and
- HMRC's new Guidelines for Compliance for Transfer Pricing;
- Various changes for updated case law, etc
In addition to being used by practitioners, this title is also used by undergraduate and post graduate students studying business degrees, and those studying for professional qualifications, such as the CIOT Advanced Diploma in International Taxation.
This title is included in Bloomsbury Professional's International Tax online service.
List of contents
1. Transfer Pricing: What Is It?
2. OECD
3. Types of Transaction: Tangible Goods
4. Types of Transaction: Intra-group Services
5. Financing
6. Intangibles
7. Profit Split
8. Business Restructuring
9. Transfer Pricing Documentation
10. Operational Transfer Pricing
11. Tax Audits and Eliminating Double Taxation
12. UK Transfer Pricing Legislation
13. Allocation of Profits to Branches
Appendix A United Kingdom Transfer Pricing Summary
Appendix B International Quick Reference Guide
About the author
Roy Donegan is a Partner in Deloitte's transfer pricing group, based in London. Roy has worked extensively on a wide range of transfer pricing matters, from advising on policies, through to documentation, implementation and liaising with tax authorities on behalf of tax payers. Within Deloitte, Roy leads a sub-group that focuses on advising privately owned groups on transfer pricing matters, ranging from large private companies and partnerships in the professional practices sector to innovative and entrepreneurial start-ups and fast-growing disruptor businesses.
