Resolving Transfer Pricing Disputes

Resolving Transfer Pricing Disputes

Author: Eduardo Baistrocchi

Publisher: Cambridge University Press

Published: 2012-12-06

Total Pages: 975

ISBN-13: 1139916289

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Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.


Introduction to Transfer Pricing

Introduction to Transfer Pricing

Author: Jerome Monsenego

Publisher:

Published: 2013-01-01

Total Pages: 163

ISBN-13: 9789144092706

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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.


The Backlash Against Investment Arbitration

The Backlash Against Investment Arbitration

Author: Michael Waibel

Publisher: Kluwer Law International B.V.

Published: 2010-01-01

Total Pages: 674

ISBN-13: 9041132023

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"This book, the outgrowth of a conference organized by the editors at Harvard Law School on April 19, 2008, aims to uncover the drivers behind the backlash against the current international investment regime."--Library of Congress Online Calalog.


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

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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.


A Global Analysis of Tax Treaty Disputes

A Global Analysis of Tax Treaty Disputes

Author: Eduardo Baistrocchi

Publisher: Cambridge University Press

Published: 2017-08-17

Total Pages: 2216

ISBN-13: 1108150381

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This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.


International VAT/GST Guidelines

International VAT/GST Guidelines

Author: OECD

Publisher: Org. for Economic Cooperation & Development

Published: 2017

Total Pages: 0

ISBN-13: 9789264272040

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This paper set forth internationally agreed principles and standards for the value added tax (VAT) treatment of the most common types of international transactions, with a particular focus on trade in services and intangibles. Its aim is to minimise inconsistencies in the application of VAT in a cross-border context with a view to reducing uncertainty and risks of double taxation and unintended non-taxation in international trade. It also includes the recommended principles and mechanisms to address the challenges for the collection of VAT on crossborder sales of digital products that had been identified in the context of the OECD/G20 Project on Base and Erosion and Profit Shifting (the BEPS Project).


Online Dispute Resolution for Consumers in the European Union

Online Dispute Resolution for Consumers in the European Union

Author: Pablo Cortés

Publisher: Routledge

Published: 2010-09-13

Total Pages: 283

ISBN-13: 1136943501

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Offers an account of ODR for consumers in the EU context, presenting a comprehensive investigation of the development of ODR for business to consumer disputes within the EU. This book examines the role of both the European legislator with the Mediation Directive and the English judiciary in encouraging the use of mediation.