Transfer Pricing Handbook: Guidance on the OECD Regulations

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John Wiley & Sons, Aug 3, 2012 - Business & Economics - 448 pages
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. 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 issues

If 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.


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ArmsLength Range
SafeHarbor Simplification
ModifyingSafe Harbor Simplification
Global Formulary Apportionment
Actual Profitsversus Projected Profits Different Profit MeasuresWhen Applying the Transactional
Selecting Profit Indicators
ServiceArrangements Overview
Puttingthe Guidelinesto
Allocation Keys
ChinaTaiwan Trade
Guidelines 7 25
Simultaneous Tax Examinations and Transfer Pricing

Selecting Transfer Pricing Methods
Comparability Analysis
General Comparability Guidance
Typical Comparability Processes BroadBased Analysis ofthe Taxpayers Circumstances Controlled Transaction andChoice of a Tested Party
Selectingor Rejecting PotentialComparables
Transfer Pricing Audits
Documentation Requirements
Intangible Property
Success Parametersto theReverse Engineering Process
TransactionalNet Margin Method
Guidelines7 34 51 Guidelines7 35 52 Guidelines 7 36 53 Guidelines 7 37 54 Guidelines7 38 55 Guidelines7 39 56 Guidelines 7 40 57 Guidelines 7 ...
Permanent Establishment Parameters
Focus on Permanent Establishment
About the Authors
Selecting among AllocationKeys
Transactional ProfitSplit Measures

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About the author (2012)

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).

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