Last edited by Tam
Thursday, July 23, 2020 | History

2 edition of Transfer pricing and business restructurings found in the catalog.

Transfer pricing and business restructurings

Transfer pricing and business restructurings

streamlining all the way

  • 251 Want to read
  • 22 Currently reading

Published by IBFD in Amsterdam .
Written in English

    Subjects:
  • International business enterprises -- Law and legislation,
  • Transfer pricing -- Law and legislation,
  • Corporate reorganizations

  • Edition Notes

    Includes bibliographical references.

    Statementedited by Anuschka Bakker.
    ContributionsBakker, Anuschka.
    Classifications
    LC ClassificationsK1322 .T73 2009
    The Physical Object
    Paginationxxx, 494 p. :
    Number of Pages494
    ID Numbers
    Open LibraryOL24066607M
    ISBN 109087220553
    ISBN 109789087220556
    LC Control Number2009497685

    Transfer Pricing Aspects of Business Restructurings There is no legal or universally accepted definition of business restructuring. In the context of this chapter, business restructuring is defined as the cross-border redeployment by a multinational enterprise of functions, assets and/or risks. UN Transfer Pricing manual, as supplemented by this chapter, apply to business restructurings to ensure that they are consistent with the arm’s length principle. B

    of intangibles in the context of business restructurings in 3 The OECD even-tually concluded its main findings with respect to transfer-pricing aspects of in-tangibles in Action 8 of the BEPS Project 4 in and subsequently adopted these changes in the OECD Transfer Pricing Guidelines (OECD TP . OECD adopting Chapter IX (Transfer Pricing Aspects of Business Restructurings) to the OECD Transfer Pricing Guidelines in Nevertheless, the tax and transfer pricin g treatment of business restructurings is seldom expressly regulated on a national level. This research deals with the transfer pricing treatment of business restructurings.

    View a sample of this title using the ReadNow feature. The new 4th Edition of Practical Guide to U.S. Transfer Pricing continues to be the authoritative legal treatise for tax counsel, tax authorities, the judiciary, and policy makers. The 4th Edition is fully revised with several new chapters, over 2, pages of analyses and practice notes, 47 chapters divided over six parts. TRANSFER PRICING & BUSINESS RESTRUCTURINGS – INTANGIBLES SYNERGIES AND SHELTERS Richard T. Ainsworth & Andrew B. Shact Introduction Transfer pricing in business restructuring is attracting global attention. In the past two years two key policy making groups have released three substantive documents on this topic.


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Transfer pricing and business restructurings Download PDF EPUB FB2

Transfer Pricing and Business Restructurings provides readers with an understanding of the key tax and transfer pricing concepts, methodologies and trends relating to business : Transfer Pricing and Business Restructurings provides readers with an understanding of the key tax and transfer pricing concepts, methodologies and trends relating to business restructurings.

Read more Read less The Amazon Book Review Author interviews, book reviews, editors' picks, and : Paperback. Transfer Pricing and Business Restructurings: Streamlining All the Way.

This book highlights the main tax issues that arise when business restructurings take place. It provides fundamental information about the drivers of business restructurings and business models, examines the application of Art. Transfer pricing refers to the pricing of cross-border intercompany transactions.

In the context of taxation, the main aim of transfer pricing is to share the income--and thus, the tax base--of multinational enterprises between the countries where they are doing by: 1. This book will draw together divergent views, current practice of key industrial economies, as well as dispassionate analysis.

Business restructuring involves a clash between several core principles. These include: the company as a legal person with an identity, rights and obligations distinct from its owners. Business Restructurings Transfer Pricing Perspective August Contents • Introduction and Relevance • OECD Guidance – TP Aspects of Business restructurings • Business restructurings – Case Studies • The Good and Worrisome • Best practices.

−Evaluate Business reasons −Consider options realistically available. special scheme of pricing control is applied to transactions involving related parties.

This system is called transfer pricing. Transfer pricing involves investigating all aspects of inter-company pricing arrangements between related business entities, including transfers of intellectual property, goods, services and financing transactions.

UPS and DSG are case studies for the application of transfer pricing rules in a business restructuring context where a critical element involves the transfer of an intangible. This paper considers how the arguments and outcomes in these cases inform the present discussion on transfer pricing and : Richard Thompson Ainsworth.

Introduction Business restructuring and transfer pricing have had a high profile in recent media reports with the spotlight focused on how much or how little tax multinationals pay.1 Multinationals argue these restructures are legitimate, reflect both the spirit and letter of the law, and are.

The Enigma of ‘Exit Charge’ and Guidance on Arm’s Length Compensation. Chapter IX of the OECD guidelines notes that in restructuring, tangible or intangible assets might be transferred, or valuable business contracts might be terminated or renegotiated typically leading to a reallocation of profits among the members of the MNE group.

Transfer Pricing and Business Restructurings Streamlining all the way Introduction Werner Stuffer and Nadine Hiller Siemens AG 1. Drivers of business restructuring Regardless of products or sectors, international companies these days face the pressure of competition in a globalized economy.

Multinational enterprises (MNEs). Chapter IX of the OECD transfer pricing guidelines notes that in a restructuring, tangible or intangible assets might be transferred away, or valuable business contracts might be terminated or renegotiated (such contracts are also intangible assets).

This chapter contains a discussion of the transfer pricing aspects of business restructurings, i.e. of the application of Article 9 (Associated enterprises) of the OECD Model Tax Convention and of these Guidelines to business Size: KB.

The purpose of this workshop is to address the recent developments in the field of transfer pricing and business restructurings with a special focus on identification of transfer pricing issues arising for MNEs whenever they decide to restructure their functions by transferring intangible property.

Discussion Draft on the Transfer Pricing Aspects of Business Restructurings 19 September – 19 February 19 September Transfer Pricing Aspects of Business Restructurings.

Public Discussion Draft. Business restructurings by multinational enterprises have been a widespread phenomenon in recent Size: KB. Business restructurings sometimes involve the transfer of an ongoing concern, i.e. a functioning, economically integrated business unit. The transfer of an ongoing concern in this context means the transfer of assets, bundled with the ability to perform certain functions and bear certain risks.

Ainsworth, Richard Thompson and Shact, Andrew, Transfer Pricing & Business Restructurings: Intangibles, Synergies, and Shelters (June 3, ). 63 Tax Notes International (August 1, ); Boston Univ. School of Law, Law and Economics Research Paper No. Cited by: 2. About this book: Fundamentals of Transfer Pricing aims to capture the concepts and fundamental principles of transfer pricing by providing theoretical and practical knowledge on transfer pricing topics.

Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. the document “Transfer Pricing Aspects of Business Restructurings: Discussion Draft for Public Comment”.

Furthermore, the approach of this draft is compared with the au-thorized OECD approach, established in the Report on the Attribution of Profits to Permanent Establishments.

German law on transfer pricing provisions will also be ex. In a transfer pricing context these transactions are defined as the cross-border redeployment of functions, assets (tangible and/or intangible) and risks to which a profit/loss potential may be attached.

It is often the case that intangibles are transferred in connection to business restructurings leading to significant audit risk. Transfer Pricing Aspects of Business Restructurings PricewaterhouseCoopers 5 The majority view that the commercial rationality test need only be met at.

Some countries believe that transactions driven by decisions which are commercially rational at the group level are capable of non-recognition at a .Transfer pricing and business restructurings: streamlining all the way. [Anuschka Bakker;] -- This book highlights the main tax issues that arise when business restructurings take place.

It provides fundamental information about the drivers of business restructurings and business models.Transfer pricing is an area of tax law which is becoming increasingly important. Our study will focus on the basics of transfer pricing: the 'arm's length principle', comparability and transfer pricing methods, but will also address business restructurings and include a case study.