Fundamentals of Transfer Pricing

About this book:
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.

What’s in this book:
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:

Part I: General Topics

I.    Introduction to Transfer Pricing
II.    Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis
III.    Transfer Pricing Methods (Part I): Traditional Transaction Methods
IV.    Transfer Pricing Methods (Part II): Transactional Profit Methods
V.    Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes
VI.    Administrative Approaches to Resolving Transfer Pricing Disputes
VII.    Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting

Part II: Specific Topics

VIII.    Attribution of Profits to Permanent Establishments
IX.    Transfer Pricing and Intra-group Services
X.    Transfer Pricing and Intra-group Financial Transactions
XI.    Transfer Pricing and Intangibles
XII.    Transfer Pricing, Supply Chain Management and Business Restructurings
XIII.    Transfer Pricing and Customs Valuation
XIV.    Transfer Pricing and EU State Aid

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...