📖 ebook - Intercompany Agreements for Transfer Pricing Compliance: A Practical Guide

Ebook Intercompany Agreements for Transfer Pricing Compliance: A Practical Guide

Beschreibung Intercompany Agreements for Transfer Pricing Compliance: A Practical Guide

/1912687186

Intercompany agreements are legal agreements which define the terms on which services, products and financial support are provided between related parties. For groups which operate internationally, intercompany agreements are the essential foundation for complying with transfer pricing regulations (the international rules which determine where profits are taxed) and for minimising the risk of double taxation.The task of maintaining an effective system of intercompany agreements often falls between two stools: tax and finance professionals may receive the blame for unexpected tax assessments resulting from transfer pricing challenges, but do not typically have the skills to manage legal documentation. Similarly, many corporate lawyers are unfamiliar with transfer pricing concepts and may not have hands-on experience of the issues involved.This book is a practical resource for finance, tax and transfer pricing professionals, and for anyone involved in designing, implementing, maintaining or reviewing intercompany agreements for multinational groups. It sets out a common-sense approach to achieving compliance so that, as far as possible, the tax, legal regulatory and governance needs of a group can be met in a holistic way.ABOUT THE AUTHORPaul Sutton is the co-founder of LCN Legal and a corporate lawyer with over 25 years’ experience of advising international clients, including airlines, telecommunications groups and media networks. He has particular expertise in working alongside tax professionals worldwide on the design, implementation and maintenance of legal structures for large corporates. His experience includes working in KPMG’s law firm in the UK, where he worked closely with international tax teams and developed his specialism in the legal issues which underpin transfer pricing compliance.Paul has been recognised and quoted as an expert by publications such as the Financial Times, the Scotsman newspaper and Financial Director Magazine. He regularly contributes to technical publications for legal and tax professionals. Through LCN Legal he has pioneered the publication of templates and other resources for tax and finance professionals.

Intercompany Agreements for Transfer Pricing Compliance: A Practical Guide PDF ePub

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International Transfer Pricing - PwC ~ reference guide covering a range of transfer pricing issues in nearly 100 territories worldwide. For up‑to‑date information from PwC’s leading transfer pricing publications, download TP to Go from your app store now. TP to Go is free to download on iOS, Android, and Blackberry. Once installed, it checks automatically for new content every time it starts. Transfer pricing at your .

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Transfer Pricing / Internal Revenue Service ~ Section 482 of the Code authorizes the IRS to adjust the income, deductions ,credits, or allowances of commonly controlled taxpayers to prevent evasion of taxes or to clearly reflect their income. The regulations under section 482 generally provide that prices charged by one affiliate to another, in an intercompany transaction involving the transfer of goods, services, or intangibles, yield .

International Transfer Pricing - PwC ~ transfer pricing publications, download TP to Go from your app store now. TP to Go is free to download on iOS, Android, and Blackberry. Once installed, it checks automatically for new content every time it starts. International transfer pricing 2013/14. All information in this book, unless otherwise stated, is up to date as of 15 September 2012. This publication has been prepared for general .

Transfer Pricing - Verrechnungspreise in multinationalen ~ Mit dem Begriff Transfer Pricing (deutsch: Verrechnungspreis) bezeichnet man im Allgemeinen die monetäre Bewertung bestimmter Güter oder Leistungen, die allerdings nicht von Dritten bezogen werden, sondern innerhalb eines Unternehmens zwischen selbständigen Bereichen ausgetauscht werden. Dies ist ein Phänomen, das besonders bei organisatorisch getrennten Unternehmensbereichen bzw. auch bei .

Practical compliance guidelines / Australian Taxation Office ~ a practical compliance solution where tax laws are creating a heavy administrative or compliance burden, or where the tax law might be uncertain in its application. These guidelines can provide you with additional certainty and compliance savings, and allow us to direct our compliance resources to higher risk areas of the law.

Transfer Pricing Country Profiles - OECD ~ Data and research on transfer pricing e.g. Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, transfer pricing country profiles, business profit taxation, intangibles, These country profiles focus on countries' domestic legislation regarding key transfer pricing principles, including the arm's length principle, transfer pricing methods, comparability analysis .

International Transfer Pricing Journal - All Articles - IBFD ~ [1 September 2009] - Transfer Pricing Practice in an Era of Recession [1 September 2009] - Transfer Pricing Documentation Requirements Likely To Come into Force as from 1 January 2010 [1 September 2009] - Transfer Pricing Practice in an Era of Recession [1 September 2009] - Hong Kong - Departmental Interpretation and Practice Note 45

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5 best practices for intercompany accounting - Journal of ~ A 2016 Deloitte poll of more than 3,800 accounting and finance professionals suggests that disparate software systems in the different legal entities pose the biggest problem (21.4% of respondents), followed by intercompany settlement (16.8%), complex intercompany agreements (16.7%), transfer-pricing compliance (13.3%), and foreign exchange .

Transfer pricing software and solutions / Thomson Reuters ~ WIth Thomson Reuters ONESOURCE software and Checkpoint research, transfer pricing and BEPS compliance is a snap. See how easy your job could be today.

Chapter 6 TRANSFER PRICING METHODS 6ntroduction to ~ usually used as comparables for transfer pricing purposes, in practice it is sometimes not possible to identify reliable comparable data in the same markets. In such cases practical solutions should be sought in good faith by taxpayers and the tax administration. Comparability issues are discussed in more detail at Chapter 5. 6 .1 .2 .7 . Solutions for cases where comparables are difficult to .

Transfer Pricing - Investopedia ~ Transfer pricing is an accounting practice that represents the price that one division in a company charges another division for goods or services provided. A transfer price is based on market .

8355614 2014 Global Transfer Pricing Country Guide ~ Transfer Pricing Country Guide should be the starting point rather than the finish line for all your transfer pricing inquiries. With 97 percent of jurisdictions evaluated, Deloitte ranked in the top two tiers in International Tax Review’s Word Tax Ratings 2104. The transfer pricing specialists in Deloitte member firms around the world have the knowledge and experience to help you on your .

International transfer pricing – concepts and risk ~ International transfer pricing – concepts and risk assessment. Australia's transfer pricing rules seek to avoid the underpayment of tax in Australia. The rules aim to make sure that businesses price their related-party international dealings in line with what is expected from independent parties in the same situation.

Verrechnungspreis – Wikipedia ~ Als Verrechnungspreis (auch Transferpreis oder Konzernverrechnungspreis) wird in der Kosten- und Leistungsrechnung derjenige Preis bezeichnet, der zwischen verschiedenen Bereichen eines Unternehmens oder zwischen verschiedenen Gesellschaften eines Konzerns für innerbetrieblich ausgetauschte Güter und Dienstleistungen (z. B. Warenlieferungen, Lizenzen, Darlehen) verrechnet wird.

Transfer Pricing and Corporate Taxation: Problems ~ Transfer pricing is often identified as the most important tax issue that multinational corporations face. This publication is an extremely useful tool for practitioners and tax directors grappling with complex and contentious transfer pricing issues of various kinds. It contains a series of highly detailed case studies, which draw on the author's two decades as a government economist .

Collier, R: Transfer Pricing and the Arm's Length ~ Intercompany Agreements for Transfer Pricing Compliance: A Practical Guide . and the necessary information is not available for the theory to be applied in practice. Yet the tax establishment cannot seem to let it go and admit something more radically different is needed. There is a short section, not even a whole chapter, on Non-ALPS alternatives. I found this disappointing, with serious .

Paul Sutton - Phoenix, Arizona / Professional Profile ~ Author of 'Intercompany Agreements for Transfer Pricing Compliance - A Practical Guide'. Business mentor and document automation architect. Business mentor and document automation architect .

Transfer pricing - Canada.ca ~ Should the CRA adjust your transfer prices, you may be subject to penalties if you did not make reasonable efforts to determine and use arm's length transfer prices. The transfer pricing penalty is equal to 10% of certain adjustments made under the Income Tax Act. See TPM-13 Referrals to the Transfer Pricing Review Committee.

Tax Guides / EY - Global ~ Browse our in-depth guides covering corporate tax, indirect tax, personal taxes, transfer pricing and other tax matters in more than 150 countries.