An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businessesA comprehensive guide for companies doing business globally, Asia-Pacific Transfer ...Pricing Handbookexplains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders.Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbookis an essential resource for doing business abroad.Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countriesCovers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the regionExplains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the lawA complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbookexplains everything foreign companies need to know about doing business abroad.
A growing concern among those interested in economic development is the realization that hundreds of billions of dollars are illicitly flowing out of developing countries to tax havens and other ...financial centers in the developed world. This volume assesses the dynamics of these flows, much of which is from corruption and tax evasion. What causes them, what are their consequences and how might they be controlled? The chapters by authors from a variety of backgrounds, including criminologists and practicing lawyers as well as economists, examine many dimensions of the phenomenon. For example, one chapter examines the political economy of the issue; to what extent is this the consequence of a more general failure of governance, so that it is more a manifestation of government weakness or can it be identified with a few specific features? Two other chapters examine major illegal markets (drug trafficking and human smuggling) to assess how they contribute to these flows. Other chapters are concerned with the corporate role in the phenomenon, particularly the possibility that transfer pricing (in which firms set prices for international trade among wholly owned affiliates) might play a major role in moving money illicitly.
Transfer pricing handbook Feinschreiber, Robert; Kent, Margaret
2012., 2012, 2012-08-03, 2012-08-02, Letnik:
588
eBook
Learn OECD guidance on business taxation in multiple countries A business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying ...more in taxes that the share of profit it generates. The Organisation for Economic Co-operation and Development (OECD) seeks to reduce the risk of business taxation in multiple countries. Transfer Pricing Handbook explores how countries can apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. It is the ultimate comprehensive guide for companies doing business globally. Helps companies properly price their goods and services for global markets Provides defenses for transfer pricing audits Provides standards for creating comparables that multijurisdictional tax administrations will accept Guides documentation requirements and timing issues If you're doing business in more than one country, Transfer Pricing Handbook is a must-have, essential guide for simplifying OECD regulations for your global company.
Într-o economie puternic marcată de globalizare, preţurile de transfer reprezintă un punct central pe agenda contribuabililor, autorităţilor fiscale şi organismelor de reglementare, influenţa lor ...manifestându-se În primul rând În domeniul fiscal, respectiv În ceea ce priveşte determinarea corectă şi alocarea corespunzătoare a bazei impozabile aferentă impozitului pe profit Între diferite jurisdicţii sau Între companii care activează În cadrul aceleiaşi jurisdicţii. Însă, preţurile de transfer transcend problematica fiscală, influenţând Într-o măsură semnificativă şi alte aspecte din viaţa unei entităţi, unul dintre acestea fiind imaginea reflectată În situaţiile financiare anuale, inclusiv fluxurile de numerar sau indicatorii de performanţă financiară şi, prin analiza acestora, deciziile de investiţii ale potenţialilor utilizatori de informaţii contabile. Prin urmare, preţurile de transfer reprezintă un punct de reper şi În activitatea de audit desfăşurată la nivelul companiilor care fac parte din grupuri naţionale şi multinaţionale şi sunt implicate În tranzacţii intra-grup semnificative, Întrucât respectarea sau nu a principiului valorii de piaţă influenţează În mod direct reflectarea elementelor de venituri, cheltuieli, rezultat, active, capitaluri proprii sau datorii În conformitate cu principiul imaginii fidele şi, astfel, În cele din urmă, opinia de audit. Standardele naţionale şi internaţionale de audit oferă recomandări şi indicaţii cu privire la modul În care trebuie tratată problematica preţurilor de transfer ca parte a misiunilor de audit, fapt ce reflectă o preocupare continuă a organismelor profesionale pentru conturarea celor mai bune practici in domeniu.
This paper describes the implementation of BEPS Action Plan 13: Definition, Benefit, Challenge, and Change. The research was conducted using qualitative. It used secondary data from OECD. Lyotard was ...used to analyzing the data. The research showed that BEPS Action Plan 13 significantly increased transfer pricing taxpayer compliance worldwide. However, amendments regarding materiality, competent authority agreement, time, and manner of information exchange are required. As a result, the policy can enhance the information that is made available, good, and consistent to the tax administration. The policy maker and tax consultant can use this research to create sufficient BEPS Action Plan 13 for taxpayers based on tax jurisdiction. Each jurisdiction has unique and different tax administrations to respond to the BEPS Action Plan 13. Especially in Indonesia, those concerned about BEPS Action Plan 13 must publish meta-narratives to speak up about the suitable policy for Indonesia’s taxpayers toward BEPS Action Plan 13. Publishing meta-narrative is available by using the Lyotard perspective. This paper presents descriptive guidance in managing transfer pricing documents, especially Country-by-Country Reporting (CbCR). The result served the idea from OECD as the guidance indicator and taxpayers or other stakeholders (who are interested in the Transfer Pricing Document). So, changes are needed to balance the requirement between OECD and stakeholders whenever the regulation could be implemented in each jurisdiction.
Transfer pricing is important to many business conglomerates and multinational enterprises. In this review, we pursue a stock-take of transfer pricing research through a bibliometric analysis. Using ...bibliometric data of 735 research articles from the Scopus database, this review sheds light on the leading authors, countries, institutions, outlets, articles, and themes of transfer pricing research over 50 years (1968–2019). Findings of this review suggest that there is a need for transfer pricing research to go beyond compliance and tax management and toward a more meaningful exercise of using transfer pricing as a strategic tool in business. Future research directions for transfer pricing conclude this review.
transfer pricing merupakan kebijakan perusahaan dalam menentukan harga transfer suatu transaksi baik itu barang, jasa, harta tak berwujud, ataupun transaksi finansial yang dilakukan oleh perusahaan ...pada anak perusahaan. Praktik transfer pricing pada dasarnya hal yang wajar dan normal dalam bisnis. Tetapi transfer pricing tersebut menjadi berarti konotatif karena biasanya berkaitan dengan praktik penghindaran pajak. Upaya memimalisir adanya kecurangan transfer pricing di Indonesia bersumber Pasal 18 Undang-Undang PPh yang menyatakan bahwa Dirjen Pajak berwenang menentukan kembali besarnya penghasilan dan pengurangan suatu wajib pajak sehubungan dengan transaksi yang dilakukan dengan pihak-pihak yang memiliki hubungan istimewa berdasarkan prinsip kewajaran dan kelaziman usaha yakni apabila transaksi tersebut dilakukan dengan pihak-pihak independen. Pada prinsip yang harus diperhatikan oleh otoritas fiskal untuk mendapakan justifikasi yang kuat terhadap koreksi pajak atas dugaan transfer Pricing yaitu, Afiliasi (associated enterprise) atau hubungan istimewa (special relationship). Metode pendekatan yaitu yuridis normatif berdasarkan peraturan perundang-undangan sebagai kaidah atau norma yang menjadi pedoman.
Over a third of international trade happens within, rather than between, corporations. This makes establishing transfer prices - the price of transactions within and between related corporations - ...pivotal, as it defines corporations' tax bills. Tax authorities worldwide follow the OECD transfer pricing guidelines and its accompanying methods for taxing corporations. This despite the guidelines' well-documented weaknesses and even though alternative and potentially simpler methods exist. Existing literature helps explain why the OECD guidelines continue to dominate but not how those in favor of the status quo will go about defending them. We offer a novel, theory-based framework, to explain how supporters of the status quo - the epistemic community - will respond, using a combination of strategies targeting the policy discourse but also policy makers, in an effort to bolster the legitimacy of the OECD guidelines. We use discourse network analysis to study the debate on simplified transfer pricing methods from 1995 to 2018 and the positions of actors engaged. Our data confirms that the epistemic community deploys a hypothesized mix of strategies to ensure the durability of the OECD guidelines and accompanying methods, at the same time undermining the position of alternative approaches.
A flourishing literature quantifies the corporate tax revenue losses from multinational profit shifting to low-tax economies. Other consequences of international tax avoidance have received little ...attention. In this paper, we empirically assess the widespread perception that international tax avoidance impacts product market outcomes and can put national competitors of multinational firms at a competitive disadvantage. The empirical identification strategy relies on changes in transfer pricing regulations that constrain multinational profit shifting by strategic mis-pricing of intra-firm trade. Based on rich data on firms in European high-tax countries, we show that tighter transfer pricing provisions raise multinational firms’ effective tax costs and lower their sales. The sales and profits of affected firms’ national competitors increase significantly, while mark-ups remain largely unchanged. We discuss policy implications of our findings.
•We empirically assess if multinational profit shifting impacts product market outcomes.•The identification strategy relies on changes in transfer pricing provisions.•We show that tighter rules lower MNEs’ sales and increase the sales of national competitors.•We discuss implications of our findings.
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