Transfer pricing and value creation
By: edited by Raffaele Petruzzi, Romero J.S. Tavares
Series: Series on international tax law -- volume 116; Schriftenreihe zum internationalen Steuerrecht -- Bd. 116
Publisher: Linde Verlag
Published: 2019
Place of publication: Wien
Language: eng
Number of pages: 556
ISBN-13: 9783707341232
Subjects: Transfer pricing; Taxation; Law and legislation; International business enterprises; Valuation
Description: Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of value creation came to permeate not only transfer pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of "value creation" reframes the interpretation and application of the arm's length principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new value creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analysing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. The book provides four parts: (1) introduction; (2) value creation and the application of the arm's length principle; (3) transfer pricing an global value chains; and (4) transfer pricing and value creation in specific industry sectors.
Notes: The present volume comprises the master's theses of the part-time students attending the 2017-19 class of the postgraduate LL.M. program "International Tax Law" at WU (Vienna University of Economics and Business).

Includes bibliographical references.
Table of contents: title: Historical evolution on transfer pricing and value creation / Olga Solovyova; title: Value creation and transfer pricing policy considerations / Shengjie Yan; title: Transfer pricing and value creation in the context of permanent establishments / Werner Egger; title: Value creation and the accurate delineation of the transaction / Matthias Werner; title: Value creation and the recognition of the actual transaction undertaken / Viktoria Kraus; title: Value creation and application of traditional transaction methods / Martin Šimunek; title: Value creation and the application of transactional profit methods / Pavlo Khodakovsky; title: Value creation and procurement function / Pavlina Kropackova; title: Value creation and the manufacturing function / Doris Schatzi; title: Value creation and the distribution function / Valeria Khmelevskaya; title: Value creation and service function / Monika Majerková; title: Transfer pricing and value creation in the RD&I functions / Bernhard Winkelbauer; title: Transfer pricing and value creation in the commodities trade sector / Dmitry Brodskiy; title: Transfer pricing and value creation in the automotive sector / Jeanine Blumer; title: Transfer pricing and value creation in the real estate sector / Tereza Gebauer; title: Transfer pricing and value creation in the consumer products sector / Paul Tiefling; title: Transfer pricing and value creation in the food and beverage sector / Monica Califano; title: Transfer pricing and value creation in a digitalized economy / Angelika Zacher; title: Transfer pricing & value creation in the pharmaceutical sector / Yusuf Jamal Siddiqui; title: Transfer pricing and value creation in the telecommunications sector / Stefan Schuster.