Transfer Pricing And Customs Valuation Download Ebook PDF Epub Online

Author : Juan Martin Jovanovich
Publisher : Kluwer Law International B.V.
Release : 2016-04-24
Page : 216
Category : Law
ISBN 13 : 9041161422
Description :


Issues of transfer pricing have come to the fore in both international tax and customs regimes. In particular, the problem of how to apply the two systems of valuation to the same transaction is of widespread concern. This well-known book, now in a fully updated second edition, is a problem-solving guide for professionals charged with valuating transactions in their client’s or company’s best interests. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, it offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized. Among other essential elements, the author discusses the following in depth: – the OECD Transfer Pricing Guidelines; – the GATT/WTO Customs Valuation Code (GVC) and other valuation rules in key jurisdictions and regional agreements; – the OECD and UN model tax conventions; – the arm’s length principle; – methods, both traditional and new, of determining whether the parties’ relationship in uenced the price; and – additions to and deductions from the customs value. This second edition discusses new developments in the eld, including a chapter on Commentary 23.1 and Case Study 14.1 of the Technical Committee on Customs Valuation of the World Customs Organization (WCO) – the rst international instruments linking transfer pricing and customs valuation. The book concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing year-end adjustments to transaction value would be consistent with Article 1 of the GVC. The book will continue to provide practitioners, customs administrations, and academics with a highly practical analysis of the intersection of transfer pricing and customs valuation. It will be welcomed by customs administrations charged with examining the acceptability of a transaction value xed between related parties and by multinational companies as a truly actionable tool they can use to optimize decision-making as it relates to transfer pricing and customs valuation in a “real world” setting.


Author : Anuschka Bakker
Belema Obuoforibo
Publisher : IBFD
Release : 2009
Page : 662
Category : Customs appraisal
ISBN 13 : 9087220596
Description :



Author :
Publisher :
Release : 2006
Page :
Category :
ISBN 13 :
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Author : Juan Jovanovich
Publisher : Springer
Release : 2002-10-30
Page : 135
Category : Business & Economics
ISBN 13 :
Description :


Although valuation is fundamental to both tax and customs liability in international transactions, values calculated by the two regimes can differ, often markedly, in situations where no clear rules of transfer pricing apply. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, Customs Valuation and Transfer Pricing offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized.Among the essential elements of this important thesis, the author discusses the following in depth: the OECD Transfer Pricing Guidelines; the GATT/WTO Valuation Code (GVC); the arm's length principle; methods, both traditional and new, of determining whether the parties' relationship influenced the price; and additions to and deductions from the customs value. The study concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing compensatory adjustments to transaction value would be consistent with Article 1 of the GVC.


Author :
Publisher :
Release : 2017
Page :
Category :
ISBN 13 :
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Author : G. Piran
Publisher :
Release : 2018
Page : 62
Category :
ISBN 13 :
Description :


Transfer pricing and customs are separate legal disciplines and rely on different legal instruments. Transfer pricing and customs, in fact, aim at solving different issues and, therefore, the authorities appointed to supervise their application might have diverging interests. This thesis examines the interaction of the valuation processes carried on under the two legal disciplines. It provides an analysis of relevant regulations and literature and case law and is completed by the consideration of administrative practices in Italy, South Korea, UK and the USA, with the purpose of identifying the instruments currently available to economic operators to deal with the problem presented. The purpose of the paper was to identify the status quo of the subject and, whenever the issue of the imperfect interaction between transfer pricing and customs valuation methods was persisting, to propose a comprehensive solution to it.


Author : Juan Martʹin Jovanovich
Publisher :
Release : 2000
Page : 294
Category : Tariff
ISBN 13 :
Description :


"There is an overlap between the transfer pricing concepts that apply under tax and under customs regimes. This thesis aims to demonstrate (i) that customs and tax laws often share common principles in respect of related-party transactions; (ii) that transfer pricing as agreed to under one discipline should be recognized under the other; (iii) that the OECD Transfer Pricing Guidelines constitute a body of rules that is appropriate to supplement the related party provisions of the GATT/WTO Valuation Code ("GVC"); and (iv) that such guidelines are generally in accordance with the provisions of the GVC and its general principles and objectives. This thesis also analyzes the tax and customs value of imported goods, and identifies which additions to or deductions from customs value might have to be taken into account in comparing tax and customs results. The thesis concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing compensatory adjustments to transaction value would be consistent with Article 1 of the GVC." --


Author : Juan Martin Jovanovich
Publisher : National Library of Canada = Bibliothèque nationale du Canada
Release : 2000
Page : 294
Category : Tariff
ISBN 13 :
Description :



Author : Anuschka Bakker
Publisher : IBFD
Release : 2009
Page : 494
Category : Corporate reorganizations
ISBN 13 : 9087220553
Description :


"Business restructurings are a reaction to global competitive pressures and changing market demand. In response to market forces, multinational enterprises (MNEs) may be able to retain their profit margins only by undertaking a restructuring. By drawing together divergent views, Transfer Pricing and Business Restructurings 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. 9 of the OECD Model Convention and considers not only the direct tax issues in business restructuring, but also VAT and customs duties."--Extracted from publisher website on March 30, 2015.


Author : Joel Cooper
Randall Fox
Publisher : World Bank Publications
Release : 2017-01-05
Page : 388
Category : Business & Economics
ISBN 13 : 1464809704
Description :


Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.


Author : Khalid Mekuanent Moroma
Publisher : GRIN Verlag
Release : 2019-12-09
Page : 26
Category : Business & Economics
ISBN 13 : 3346078892
Description :


Thesis (M.A.) from the year 2019 in the subject Business economics - Accounting and Taxes, Ethiopian Civil Service University, course: procurement and asset management, language: English, abstract: The general objective of this work is to assess the factors that affect Ethiopian importers during customs valuation. The work was conducted to assess the practices and challenges of customs valuation. In particular, the work attempted to achieve the following specific research objectives: The author seeks to explain practices of custom valuation, identify the major factors that affect importers during the procedures of customs valuation, analyse and describe challenges in customs assessment processes and discover the customs operational problems in Ethiopia, in order to identify inspection or physical examination problems during the custom valuation process while enhancing the objective of trade control. Indirect taxes contribute the significant portion of tax revenues in developing countries in general and Ethiopia in particular. Custom duties and import taxes are among the important indirect taxes levied on imported commodities in Ethiopia. Despite the fact that foreign trade taxes and duties provide significant revenues to Ethiopia, there is a serious and complex problem of invoicing of import values by importers. Duties and taxes escape the net resulting in gross economic distortions such as uneven playing field and unfair competition for legal traders. Such circumstances also result in loss of revenues to government.


Author : Anuschka Bakker
Marc M. Levey
Publisher : IBFD
Release : 2012
Page : 558
Category : Corporations
ISBN 13 : 9087221525
Description :


This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.


Author : WCO.
Publisher :
Release : 2018
Page : 113
Category :
ISBN 13 :
Description :


This guide concerns the relationship between customs valuation and transfer pricing. The 2018 edition includes updates to reflect developments on transfer pricing at the OECD including the OECD/G20 BEPS Project, information on recent texts concluded by the Technical Committee on Customs Valuation and updates to national initiatives (Annex I).


Author : OECD
Publisher : OECD Publishing
Release : 2017-07-10
Page : 608
Category :
ISBN 13 : 9264265120
Description :


This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.


Author : C. Satapathy
Publisher :
Release : 2002
Page : 251
Category : Tariff
ISBN 13 :
Description :


This handy readable book is what one would expect from so accomplished and talented a person as C. Satapathy. His association with the WTO and the Directorate of Valuation has enabled him to illuminate many dark and elusive corners of this intriguing subject; and to analyse the principles of valuation critically and pragmatically. The principles, which are otherwise baffling and unfathomable to an average reader, have not only been explained in an extremely lucid and simple manner but have also been brilliantly illustrated.


Author : Sheri Rosenow
Brian J. O'Shea
Publisher : Cambridge University Press
Release : 2010-12-02
Page :
Category : Law
ISBN 13 : 1139495364
Description :


This guide to the WTO Customs Valuation Agreement is based on the authors' experiences of teaching its finer points to customs officials and policy-makers around the world. Covering the methods of valuation and the provisions on enforcement, implementation and dispute settlement, the authors give practical examples, explain interpretative decisions of national and international customs bodies, and analyse the history of its negotiation. Written as a learning tool, it helps both new and experienced policy-makers, customs officials, importers and exporters to gain a deeper understanding of the Agreement's function and aims.


Author : Anuschka Bakker
Publisher : IBFD
Release : 2011
Page : 768
Category : Dispute resolution (Law)
ISBN 13 : 9087221002
Description :



Author : Michael Lang
Giammarco Cottani
Publisher : Kluwer Law International B.V.
Release : 2018-12-21
Page : 576
Category : Law
ISBN 13 : 904119021X
Description :


Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint 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), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.


Author : Marc M. Levey
Steven C. Wrappe
Publisher : CCH Incorporated
Release : 2007
Page : 780
Category : Business & Economics
ISBN 13 : 9780808016564
Description :


Transfer pricing is one of the most significant tax issues for corporations having international operations. It attracts the scrutiny of tax authorities worldwide and continues to draw attention of more and more countries' tax legislatures. Because of the heavy impact of income allocations on the bottom line of a corporation's business, especially potentially forced ones, international tax and business professionals need to be very careful about their tax planning and compliance efforts in order to meet the established transfer pricing standards.Practical Guide to Transfer Pricing Rules and Compliance offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Throughout the book, the authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures. The book's practical coverage and approach include: *Comprehensive analysis of the U.S. rules, case law and guidance on transfer pricing for tangible goods, intangibles, and services *Complex cost-sharing planning principles, including buy-in* *Cutting edge e-commerce transfer pricing issues *U.S. penalty and documentation rules *Documentation with checklists, questionnaires and model report *U.S. penalty rules comparedto those of other important countries *Overlap between transfer pricing and Customs valuation issues *Customs ruling based on an APA *In-depth, step-by-step analysis of the favored approach to transfer pricing controversy, including: --Developing a substantive/procedural strategy (with detailed flow-chart) --Preparing for examination --Identifying post-examination opportunities to resolve the dispute Special appendices provide a variety of "practice tools" designed to facilitate the understanding of the IRS' provisions and their translation into action, e.g., IRS forms, tables and charts of relevant cases, and comparisons of international transfer pricing rules within particular contexts. The thorough elaboration of the topics discussed, paired with clear and understandable writing, makes this new volume an excellent reference for both the experienced practitioner and the newcomer to the transfer pricing field.


Author : Mukesh Butani
Publisher :
Release : 2007
Page : 1267
Category : Transfer pricing
ISBN 13 :
Description :


Reference guide to the Indian transfer pricing laws and method. The book provides comprehensive coverage and practical guidance on transfer pricing issues, including an analysis of the Indian legislation and transfer pricing methods; documentation requirements; a comparison of the Indian legislation with the OECD guidelines; tax planning techniques related to transfer pricing; discussions of the transfer pricing regime in Australia, Canada, China, France, Germany, Japan, Singapore, the United Kingdom and the United States. Furthermore, it contains brief overviews of the transfer pricing regime in 18 other countries; and the OECD transfer pricing guidelines for multinational enterprises and tax administrations (July 1995).