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Informationen zum Autor Robert Feinschreiber (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. He has had numerous career highlights (e.g., member of the litigation team for the first Asian transfer pricing case (Toyota)). In addition, he is a consultant with the United Nations (Brazil, China, and Russia). Feinschreiber is on the editorial board of Wolters Kluwer - CCH, and Thomson - RIA. He has written over 25 books and is the co-editor of Corporate Business Taxation Monthly (CCH). He speaks at numerous conferences in the United States and Asia. Margaret Kent (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. She focuses on law and international taxation. She has been involved in a number of international transactions (i.e., structured the termination of the $2 billion per year aid from Russia to Cuba; structured transfer pricing in Latin America: Argentina, Chile, Colombia, Costa Rica, and Venezuela). Kent is also the co-editor of Corporate Business Taxation Monthly (CCH). Klappentext Learn OECD guidance on business taxation in multiple countriesA business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying more in taxes that the share of profit it generates. The Organisation for Economic Co-operation and Development (OECD) seeks to reduce the risk of business taxation in multiple countries. Transfer Pricing Handbook explores how countries can apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. It is the ultimate comprehensive guide for companies doing business globally.* Helps companies properly price their goods and services for global markets* Provides defenses for transfer pricing audits* Provides standards for creating comparables that multijurisdictional tax administrations will accept* Guides documentation requirements and timing issuesIf you're doing business in more than one country, Transfer Pricing Handbook is a must-have, essential guide for simplifying OECD regulations for your global company. Zusammenfassung Learn OECD guidance on business taxation in multiple countries A business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying more in taxes that the share of profit it generates. Inhaltsverzeichnis Preface xvii Part I: Basic Transfer Pricing Standards 1 Chapter 1: Introduction 3 Control 4 Tax Havens 5 Complexities 5 Chapter 2: Arm's Length Principle 7 General Explanation of the Arm's Length Principle 8 Formal Statement as to the Arm's Length Principle 10 Comparability Considerations 11 Rationale behind the Arm's Length Principle 11 Compensation Issues 12 Applying the Arm's Length Principle to Contribution Analysis 13 Oligopolistic Conditions 14 Transactions That Independent Enterprises Would Not Undertake 15 Administrative Burdens of the Arm's Length Principle 15 Maintaining the Arm's Length Principle as the International Consensus 16 Rejection of Alternative Transfer Pricing Approaches 17 Notes 18 Chapter 3: Arm's Length Range 19 Single-Figure Approach to the Arm's Length Range 19 Reliability Requirement 20 Comparability Considerations 20 Consequences of Applying More Than One Transfer Pricing Method 21 Selecting the ''Most Appropriate Point'' in the Range 22 Extreme Results: Comparability Considerations 23 Notes 24 Chapter 4: Safe Harbor Simplification 27 Safe Harbor Burdens and Benefits 28 Defining ''Safe Harbor'' 29 Scope of the Safe Harbor Provisions 30 How Arbitrary are the Safe Harbor Provisions? 31 Factors Supporting the Use of Safe Harbors 31 ...
Sommario
PART I: BASIC TRANSFER PRICING STANDARDS 1
Chapter 1: Introduction 3
Chapter 2: Arm's Length Principle 7
Chapter 3: Arm's Length Range 19
Chapter 4: Safe Harbor Simplification 27
Chapter 5: Modifying Safe Harbor Simplification 47
Chapter 6: Global Formulary Apportionment 57
PART II: TRANSFER PRICING METHODOLOGIES 69
Chapter 7: Transactional Profit Split Measures 71
Chapter 8: Profit Split Illustrations 91
Chapter 9: Residual Profit Split Examples 99
Chapter 10: Transactional Net Margin Method 107
Chapter 11: Selecting Profit Indicators 133
Chapter 12: Selecting Transfer Pricing Methods 141
PART III: COMPARABILITY ANALYSIS 147
Chapter 13: How Comparability Analysis Works 149
Chapter 14: Comparability Techniques 177
Chapter 15: Timing and Comparability 205
PART IV: ADMINISTRATIVE APPROACHES 213
Chapter 16: Transfer Pricing Audits 215
Chapter 17: Monitoring the Guidelines 227
PART V: ADVANCED OECD ANALYSIS 239
Chapter 18: Documentation Requirements 241
Chapter 19: Intangible Property 247
Chapter 20: Service Arrangements 263
Chapter 21: Cost Contribution Arrangements 289
Chapter 22: Business Restructuring 315
PART VI: PUTTING THE GUIDELINES TO WORK 327
Chapter 23: Malaysia-Singapore Allocation Keys 329
Chapter 24: China-Taiwan Trade 345
Chapter 25: Reverse Engineering the Transfer Pricing Process 357
PART VII: CONNECTING TRANSFER PRICING AND PERMANENT ESTABLISHMENT 383
Chapter 26: Permanent Establishment Parameters 385
Chapter 27: Focus on Permanent Establishment 397
Index 417
