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Applying the Arm's Length Principle to Intra-group Financial Transactions
It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial t...
Transfer Pricing and Value Creation
Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax...
Transfer Pricing and Financial Transactions
Transfer pricing and financial transactions: Issues and developments Since years, issues related to transfer pricing and intra-group financing are prominent in the agendas of both taxpayers and governments. The extreme relevance of these topics and the need to address them has attracted the interest of various international organizations for a long time. Already in 1972, the OECD emphasized that these topics required further attention, and the 1979 OECD Transfer Pricing Report dedicated an entire chapter to issues concerning loans. However, the first OECD Transfer Pricing Guidelines issued in 1995 did not include a chapter on these issues. Twenty-five years later, in February 2020, the OECD ...
Transfer Pricing Developments around the world 2023
Information Law Series #48 About this book: Imposing Data Sharing among Private Actors is a vital book shedding light on the nature of certain economic and societal balancing exercises required for any compulsory business-to-business (B2B) data-sharing initiatives because data sharing involves both benefits and potential costs. While the economic value originating from data sharing seems evident, identifying the legal framework to be applied to it is a challenge. This is due to the multiple claims and rights aimed at controlling, accessing or benefiting from data processing. What’s in this book: Whether these initiatives pursue economic, societal or empowerment objectives, their potential ...
The Future of the Profit Split Method
The Future of the Profit Split Method Edited by Robert Danon, Guglielmo Maisto, Vikram Chand & Gabriella Cappelleri Among the various transfer pricing methods, the profit split method (PSM) is under the spotlight after the OECD’s Base Erosion and Profit Shifting (BEPS) project. However, both expert analysis and experience indicate that this method is not straightforward either for taxpayers to apply or for tax administrations to evaluate. In this thorough and detailed commentary – the first book to analyse this increasingly adopted transfer pricing method – notable scholars and practitioners working in the international tax community express their views on the method, answering some un...
Die Reise in die Vergangenheit
Zwei Kinder reisen in die Vergangenheit und treffen zunächst die Urahnen der Familie Oberkalkofen und einen Teil deren Ahnenzweige. Die Überraschung ist groß, als sie eine Verzweigung zum europäischen Hochadel finden und keinen geringeren, als Karl den Großen treffen. Auf der Reise in die Vergangenheit lernen sie Geschichte kennen, die ihnen in der Schule so nicht vermittelt wurde und sie erfahren einiges über ihre Herkunft. Im Anhang findet jedes Familienmitglied in diversen Listen den eigenen Namen wieder.
Transfer Pricing Developments Around the World 2020
Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries’ legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised. Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepare...
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Justiça Fiscal Internacional e Tributação de Lucros de Grupos Multinacionais
A presente obra trata a tributação de lucros de empresas multinacionais à luz de uma noção de Justiça Fiscal Internacional. Após desenvolver esta noção, o autor da obra analisa o regime jurídico-fiscal aplicável às transações entre empresas do mesmo grupo multinacional constante do Direito português e da generalidade das Convenções para evitar a dupla tributação internacional dos rendimentos. Em especial, o autor desenvolve uma apreciação crítica do regime de preços de transferência, considerando as convenções modelo da OCDE. Na conclusão, o autor propõe tributar aqueles lucros através da adoção de métodos de repartição formulaica - «formulary apportionment» - mais debatendo formas de implementação concreta destes métodos tendo em conta o direito constituído.
