The Arm's Length Principle : Between Legal Fiction and Economic Reality / Raffaele Petruzzi -- Risks Redefined in Transfer Pricing Post-BEPS / Sébastien Gonnet -- Transfer Pricing Aspects of Intangibles : The License Model / J. Scott Wilkie -- Transfer Pricing Aspects of Intangibles : The Cost Contribution Arrangement Model / Yariv Brauner -- Interest Deductions and Transfer Pricing Aspects of Intra-Group Financing / Antonio Russo -- Transfer Pricing Aspects of Low Value-Adding Services / Guglielmo Maisto -- Commissionaire Arrangements/Low Risk Distributors and Attribution of Profits to Permanent Establishments / Giammarco Cottani -- Transfer Pricing and Documentation Requirements / Christian Kaeser & Sven Bremer.
Summary:
The OECD's Base Erosion and Profit Shifting (BEPS) project promises to make effective inroads into the much criticized corporate tax strategy known as aggressive transfer pricing, whereby the profitability of subsidiaries in different jurisdictions is 'managed' via mispricing with the intent of minimizing the corporation's overall tax burden. Although the OECD BEPS project is an ongoing endeavor, its accomplishments to date and developing trends are discernible. This book, including contributions by outstanding and renowned transfer pricing experts both from practice and academia, analyses these trends, and proposes reforms which would ensure that transfer pricing outcomes are better aligned with economic activities and value creation, which achieves a more equitable distribution of profits among different countries.
Series:
EUCOTAX series on European taxation, 1566-0737 ; volume 50
This resource is supported by the Institute of Museum and Library Services under the provisions of the Library Services and Technology Act as administered by State Library of Iowa.