Fundamentals of International Transfer Pricing in Law and Economics [electronic resource] /
Schön, Wolfgang.editor.
Konrad, Kai A.editor.
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm's length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Description based upon print version of record.
Includes bibliographical references.
From the contents: The Roles and Functions of Transfer Pricing in Organisations -- The OECD Approach to Transfer Pricing -- Transfer Pricing in Practice -- Separate Accounting, Profit Split and Formulary Apportionment.
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm's length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
International law.
Trade.
Public finance.
Private international law.
Conflict of laws.
Law and economics.
International Economic Law, Trade Law.
Public Economics.
Private International Law, International & Foreign Law, Comparative Law .
Law and Economics.