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. 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 book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by detailing the basics of transfer pricing and then proceeding to specific topics that are highly relevant in today’s tax environment.
This book encompasses contributions from various authors, including policymakers, practitioners and academics who have extensive experience in this field. For ease of understanding, the book is presented in two parts: General Topics and Specific Topics.
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. Considering the evolving nature of transfer pricing in the specific topics mentioned above, this book will be periodically updated in order to provide up-to-date guidance to its first publication.
This book is also used as a reference tool in the Advanced Transfer Pricing Courses organized by the WU Transfer Pricing Center. 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.
List of Figures
List of Tables
Introduction to Transfer Pricing
Petruzzi, R., Cottani, G., Sollund, S. & Prasanna, S.
Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis
Prasanna, S. & Petruzzi, R.
Transfer Pricing Methods (Part I): Traditional Transaction Methods
Brown, M. & Orlandi, M.
Transfer Pricing Methods (Part II): Transactional Profit Methods
Gonnet, S. & Madelpuech, G.
Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes
Buriak, S. & Striato, M.
Administrative Approach to Resolving Transfer Pricing Disputes
Piccone, P.F., Burkadze, E. & Peng, C.
Transfer Pricing Documentation: Master File, Local File and Country-by-Country Reporting
Attribution of Profits to Permanent Establishments
Transfer Pricing and Intra-group Services
Peng, C. & Petruzzi, R.
Transfer Pricing and Intra-group Financial Transactions
Transfer Pricing and Intangibles
Cottani, G. & Ludovici, P.
Transfer Pricing, Supply Chain Management and Business Restructurings
Prasanna, S. & Quattrocchi, Z.
Transfer Pricing and Customs Valuation
Cremer, I. & Lim, B.
Transfer Pricing and EU State Aid
Miladinovic, A. & Szudoczky, R.
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