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The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm's length standard for the determination of transfer prices is under increasing pressure.
Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights.
With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Sommario
From the contents: The Roles and Functions of Transfer Pricing in Organisations.- The OECD Approach to Transfer Pricing.- Transfer Pricing in Practice.- Separate Accounting, Profit Split and Formulary Apportionment.
Info autore
Prof. Dr. Kai A. Konrad ist Direktor am Max-Planck-Institut für Geistiges Eigentum, Wettbewerbs- und Steuerrecht in München. Er ist einer der forschungsstärksten deutschen Ökonomen und ein vielgefragter Berater in Medien und Politik, u.a. im Wissenschaftlichen Beirat beim Bundesministerium der Finanzen.
Riassunto
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure.
Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights.
With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
