Global Transfer Pricing: Principles and Practice: Third Edition

ISBN-13: 9781780439822 / Angielski / Miękka / 2016 / 288 str.

John Henshall

Opis

Now in its third 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, including the recent changes to OECD transfer pricing guidance following the Base Erosion and Profit Shifting (BEPS) initiative. 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. The updated third edition has been revised to cover the 2015 OECD BEPS report on Actions 8-10 and Action 13, released in September 2015. It features new chapters on profit split and operational transfer pricing with significant revisions to many other chapters. It also includes a quick comparative reference to differing global transfer pricing rules and access to Deloitte's 2016 Global Transfer Pricing Guide, an indispensible source of information on the transfer pricing regimes in more than 65 jurisdictions around the world. This authoritative and comprehensive guide covers the following key topics: Transfer pricing: what is it? OECD Types of transactions: tangible goods Types of transactions: intra-group services Financing Intangible property Profit split Business restructuring Transfer pricing documentation Operational transfer pricing Tax audits and eliminating double taxation UK transfer pricing legislation Transfer pricing is now 'centre stage' for tax directors, senior management and tax advisers along with journalists, politicians, pressure groups and the public. Yet many outside of the tax profession, even those who hold strong views about transfer pricing, do not actually understand what it is and how it works. Global Transfer Pricing: Principles and Practice is essential reading for anyone who wants to learn more about this important international tax compliance tool. John Henshall has over 30 years' experience in international taxation and for the past 14 years has been a transfer pricing partner at Deloitte. He represents Deloitte at OECD and was a delegate to both WP1 (considering Article 5 of the Model Tax Treaty) and WP6 (considering revisions to the OECD Transfer Pricing Guidelines). He is regularly published on transfer pricing matters. Subject: Tax Law, Commercial Law]

Spis treści

Chapter 1 Transfer pricing: what is it? Chapter 2 OECD Chapter 3 Types of transaction: Tangible goods Chapter 4 Types of transaction: Intra-group services Chapter 5 Financing Chapter 6 Intangible property Chapter 7 Profit split Chapter 8 Business restructuring Chapter 9 Transfer-pricing documentation Chapter 10 Operational transfer pricing Chapter 11 Tax audits and eliminating double taxation Chapter 12 UK transfer-pricing legislation Appendix A United Kingdom Transfer Pricing Summary Appendix B International Quick Reference Guide 2016