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Tax Director's Guide to International Transfer Pricing: 2010 Edition

  • ID: 603388
  • Book
  • May 2010
  • Region: Global
  • 560 Pages
  • Global Business Information Strategies, Inc
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More than fifty of the world's leading transfer pricing professionals offer their advice and insights on how to navigate complex issues, including: When is an APA Advantageous?, Understanding the New U.S. Services Regulations, Transfer Pricing Implications of Reorganizations, Valuing Intangibles Under Cost Sharing Arrangements, and How to Apply the Best Method Rule. The book also provides a country-by-country review of transfer pricing laws in seventeen major economies, addressing questions such as: What transfer pricing methods are accepted?, Do the local tax authorities favor a given method?, What dispute resolution mechanisms are available?, Are APAs allowed and, if so, what are the rules, To what extent are international guidelines followed?, How is the acceptability of comparables determined?, What are the documentation requirements?, and How are non-compliance penalties calculated?

This newly updated 2010 Edition builds on the success of the original Tax Director’s Guide to International Transfer Pricing, which has been relied upon by international tax professionals around the world. The articles in this new edition reflect the intense competition for tax dollars among various countries in a time of global recession, during which many tightened their transfer pricing rules and increased enforcement. The majority of the articles contain significant substantive updates. In addition, the book includes five new country overview articles discussing transfer pricing rules and practices in Australia, Hong Kong, India, Japan, and Singapore. This edition also includes an entirely new China section in response to the major transfer pricing legislation that recently went into effect, as well as a new article on supply chain management.

In-house tax specialists and outside advisors alike will find this book to be an invaluable resource in their efforts to manage global tax exposure.
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I. Introduction
- From the Editor
- Overview of the Transfer Pricing Analysis Process
- Executive Summaries

II. Advance Pricing Agreements
- Using Advance Pricing Agreements to Mitigate Transfer Pricing Risk
- Documentation Requirements, FIN 48, and APAs: Have New
- Disclosure Requirements Introduced Risk Factors that Make
- Advance Pricing Agreements More Advantageous?

III. Cost Sharing Arrangements
- A Discussion of the Latest IRS Views on the Investor Model and Intangible Valuation Under Cost Sharing Arrangements

IV. Intangibles
- Issues Arising in the Application of the Comparable Uncontrolled
- Transaction Method
- Marketing Intangibles and Transfer Pricing: Economic Issues and Tax Enigmas8
- Marketing Intangibles Require Close Legal and Tax Scrutiny

V. Organizational Structure
- Business Restructuring— “Conversion” Issues and a Framework for Analysis
- Applying the Arm’s Length Principle to Valuing “Exit Charges”
- Business Restructuring Expenses — Tax Challenges and Opportunities
- Key Considerations when Applying the New Service Regulations –
- Treas. Reg. § 1.482-9T
- A Practical Process and Approach to Implementing the New
- Transfer Pricing Service Regulations

VII. Supply Chain Management
- Issues in Supply Chain Management

VIII. Trade Finance
- Commodities Trading and Global Dealing: Transfer Pricing Challenges and Proposed Methods

IX. Treaties
- Mandatory Arbitration Procedures: A New Tack for Resolving Double
- Taxation Disputes between Competent Authorities

X. Country Overviews
- Overview of the Transfer Pricing Environment in Argentina
- Australian Transfer Pricing Rules in Practice
- Transfer Pricing in Belgium
- Transfer Pricing in Brazil
- Overview of Canadian Transfer Pricing
- China’s Transfer Pricing Regime
- Denmark – Transfer pricing overview
- Overview of Transfer Pricing in France
- German Transfer Pricing Rules in Practice
- Hong Kong Introduces Transfer Pricing Guidelines
- Transfer Pricing in India
- Transfer Pricing Developments in Japan: Law and Practice
- Transfer Pricing in Mexico
- Transfer Pricing: The Dutch Approach (the Netherlands)
- Transfer Pricing in Norway
- Singapore Transfer Pricing Requirements
- UK Tax Authorities Plan Stricter Enforcement of Transfer Pricing Rules: What will these Changes Mean for International Companies?

XI. Supplemental Materials
- United States Advance Pricing Agreement Revenue Procedure
- (IRS Revenue Procedure 2006-9)
- European Union Transfer Pricing Documentation Guidelines (EU TPD)
- China Special Tax Adjustment Implemenation Measures
- China Implementation Measures List of Attached Forms
- Japan Directive on the Operation of Transfer Pricing
- Norway Transfer Pricing Regulations

XII. Glossary
- A Note About Transfer Pricing Terminology
- Advance Pricing Agreements
- Arm’s-Length Principle
- Best Method Rule
- Comparable Profits Method
- Comparable Uncontrolled Price Method
- Cost Plus Method
- Cost of Services Plus Method
- Cost-Sharing Arrangements
- Gross Services Margin
- Indirect Costs
- Intangible Property
- Profit Split Method
- Related-Party Transaction
- Resale Price Method
- Services Cost Method

XIII. Directory of Contributors
- Brian Andreoli
- Svein G. Andresen
- Robert D. Baldassarre
- Anthony J. Barbera
- Marius Basteviken
- Anjali Bhasin
- Patrick Breslin
- George Carlson
- Philip W. Carmichael
- Jose Casas Chavelas
- Patrick Cauwenbergh
- Tanmoy Chakrabarti
- Pamela T. Church
- Jeffrey Cole
- Xavier Daluzeau
- Christopher Desmond
- Hareesh Dhawale
- Horacio Dinice
- Pierre-Jean Douvier
- Sean F. Foley
- L. David Fox
- Sheila Geraghty
- Tamara Berner Gracon
- Michael Granfield
- Thijs Heijenrath
- Tobin Hopkins
- Lyndon James
- Erik Jan van Sten
- Satoko Kawamura
- Yukiko Komori
- Ted Keen
- Elizabeth King
- Andreas Köster-Böckenförde
- Joanna Lam Luk Yu
- Ryan Lange
- Ben Lannan
- Marc M. Levey
- Fernando Pereira de Matos
- Niels Melius
- Robert Miall
- D. Clarke Norton
- Alexander R. T. Odle
- Ken Okawara
- Danny Oosterhoff
- Kari Pahlman
- Michael Plodek
- Nathan Richards
- Silvia B. Rodriguez
- J. Linwood Smith
- Geoffrey K. Soh
- Monique van Herksen
- Kimberley Webb
- Jens Wittendorf
Note: Product cover images may vary from those shown
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Note: Product cover images may vary from those shown