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Transfer pricing and the arm's length principle after BEPS

Transfer pricing and the arm's length principle after BEPS (Loan 3 times)

Material type
단행본
Personal Author
Collier, Richard S., author. Andrus, Joseph L., author.
Title Statement
Transfer pricing and the arm's length principle after BEPS / Richard S Collier, Joseph L Andrus.
Publication, Distribution, etc
Oxford, UK :   Oxford University Press,   c2017.  
Physical Medium
xviii, 306 p. ; 26 cm.
ISBN
0198802919 9780198802914
요약
This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS project, and describes the principal problems that had arisen with those rules. The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and the problems that remain after BEPS.0It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic.
Bibliography, Etc. Note
Includes bibliographical references and index.
Subject Added Entry-Topical Term
Transfer pricing. Transfer pricing. Tax evasion. International business enterprises --Taxation. Tax administration and procedure.
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020 ▼a 0198802919
020 ▼a 9780198802914
035 ▼a (KERIS)REF000018565428
040 ▼a YDX ▼b eng ▼c YDX ▼d LSD ▼d CDX ▼d OCLCF ▼d GUL ▼d EQO ▼d 211009
050 4 ▼a HD62.45 ▼b .C64 2017
082 0 4 ▼a 658.816 ▼2 23
084 ▼a 658.816 ▼2 DDCK
090 ▼a 658.816 ▼b C699t
100 1 ▼a Collier, Richard S., ▼e author.
245 1 0 ▼a Transfer pricing and the arm's length principle after BEPS / ▼c Richard S Collier, Joseph L Andrus.
260 ▼a Oxford, UK : ▼b Oxford University Press, ▼c c2017.
300 ▼a xviii, 306 p. ; ▼c 26 cm.
336 ▼a text ▼2 rdacontent
337 ▼a unmediated ▼2 rdamedia
338 ▼a volume ▼2 rdacarrier
504 ▼a Includes bibliographical references and index.
520 8 ▼a This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS project, and describes the principal problems that had arisen with those rules. The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and the problems that remain after BEPS.0It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic.
650 0 ▼a Transfer pricing.
650 7 ▼a Transfer pricing. ▼2 fast.
650 0 ▼a Tax evasion.
650 0 ▼a International business enterprises ▼x Taxation.
650 0 ▼a Tax administration and procedure.
700 1 ▼a Andrus, Joseph L., ▼e author.
945 ▼a KLPA

Holdings Information

No. Location Call Number Accession No. Availability Due Date Make a Reservation Service
No. 1 Location Main Library/Western Books/ Call Number 658.816 C699t Accession No. 111845078 Availability Available Due Date Make a Reservation Service B M

Contents information

Table of Contents

Introduction
1: The Emergence of the ALP
2: The Development of the ALP
3: Practical Application of the Arm''s Length Principle
4: Practical and Theoretical Problems Encountered in Applying the Arm''s Length Principle
5: Capital
6: BEPS Modifications to Transfer Pricing Rules
7: Evaluation of BEPS Transfer Pricing Measures
8: Prospects for the ALP After BEPS

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