An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property
An Analysis of Adequate OECD Transfer Pricing Methods for Intangible Property

Author: Melanie Keller

Publisher: GRIN Verlag

Published: 2015-07-24

Total Pages: 32

ISBN-13: 3668021937

DOWNLOAD EBOOK

Bachelor Thesis from the year 2015 in the subject Economics - International Economic Relations, Management Center Innsbruck, language: English, abstract: Due to increased globalisation over the last years and enhanced activities of multinational enterprises (MNEs), intra-firm trade has become more and more important. Intra-firm trade is estimated to constitute about one third of the global trade; and about 50% of all exports within the member states of the Organisation for Economic Co-operation and Development (OECD) are intra-firm exports. In order to determine the expenses and revenues for the associated companies, transfer prices (TP) have to be set for the respective goods of intra-group transfers (Organisation for Economic Co-operation and Development [OECD]). Intra-group transfers can be defined as the transaction of tangible or intangible property from one entity of a MNE to another entity, considered as sale and “may apply to departments, divisions, subsidiaries, or affiliate business units” . A TP therefore is the internal monetary value im-posed on goods, services or unmanufactured material that is transferred within a MNE group. According to the OECD (2010) intra-firm transfers are likewise de-fined as controlled transactions (i.e., transactions between two associated enterprises).

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

Author: OECD

Publisher: OECD Publishing

Published: 2022-01-20

Total Pages: 658

ISBN-13: 9264921915

DOWNLOAD EBOOK

In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.

Introduction to Transfer Pricing
Introduction to Transfer Pricing

Author: Jerome Monsenego

Publisher:

Published: 2013-01-01

Total Pages: 163

ISBN-13: 9789144092706

DOWNLOAD EBOOK

Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.

Addressing Base Erosion and Profit Shifting
Addressing Base Erosion and Profit Shifting

Author: OECD

Publisher: OECD Publishing

Published: 2013-02-12

Total Pages: 91

ISBN-13: 9264192743

DOWNLOAD EBOOK

This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS
OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS

Author: OECD

Publisher: OECD Publishing

Published: 2017-07-27

Total Pages: 104

ISBN-13: 9264278796

DOWNLOAD EBOOK

This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).