
Transfer Pricing
Description
The field of transfer pricing is perceived as extraordinarily complex and resembles worldwide a jungle of regulations in which only specialists know their way around, although in principle everything could be reduced to a globally unified standard: the arm's length principle. This book is therefore addressed to all those who are (or want to be) interested in the topic, especially newcomers to the field of transfer pricing, students, especially in the field of law and economics, who are interested in the area of tax law or transfer pricing, students of law and economics, who are dedicated to tax law or tax theory, trainee tax consultants, consultants in the field of corporate taxation and transfer pricing, employees of the tax authorities, employees in corporate tax departments and in controlling, public prosecutors and judges.
This English language version of the original publication concentrates on the application of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and refers to the United Nations Practical Manual on Transfer Pricing for Developing Countries. The worldwide transfer pricing standards are defined here, allowing us to write a book that is generally applicable to all jurisdictions.

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Persons
Herausgegeben von:
Eva Greil, Syndikusrechtsanwältin, LL.M.
Dr. Stefan Greil, LL.M.
Unter Mitwirkung namhafter Autoren aus Unternehmenspraxis, Beratung, Finanzverwaltung und Wissenschaft
Content
1. Introduction – the arm’s length principle
2. The first step: Value Chain Analysis
3. Transfer Pricing Methods
4. Comparability Analysis
5. Supply of materials
6. Intangibles
7. Services
8. Cost Sharing Arrangements
9. Cost Contribution Arrangements
10. Business restructuring/transfer of functions
11. Financial Transactions
12. Tax challenges arising from the digitalisation of the economy
13. Permanent Establishments
14. Obligation to cooperate – Transfer pricing documentation
15. Country-by-Country Reporting
16. Litigation, dispute avoidance and resolution