Transfer Pricing is one of the most relevant tax issue for MNEs. International tax practitioners are faced with complex intra-company transactions and different formal requirements of the jurisdiction involved. The proof of the arm´s length principle and the local documentation requirements are some of the main issues international advisors and tax departments of MNEs are faced with.
The book is devided into four parts. The first part focuses on the different transfer pricing methods as the comparable profit method (CPM), the resale price and cost plus methods or the comparable uncontrolled price method to be applied in the United States of America. Global dealing regulations and it´s practial implications are described. Part two highlights some alternative approaches to transfer pricing aspects as the return on capital approach or the joint venture profit split. Part three provides eight case studies that illustrate the methods and aspects highlighted in part two. The case studies are structured in the same way and compare different methods and transfer pricing regimes. The book ends with the concluding observations and a detailed index.
The book of Elizabeth King is written for the benefit of tax practitioners. The focus is on the various transfer pricing cases. The case studies reflect in particular the US views as for example the FIN 48 specifications. We recommend this book to tax advisors and inhouse tax specialists handling transfer pricing aspects in particular related to the US.
Transfer Pricing and Corporate Taxation
Problems, Practical Implications and Proposed Solutions
Softcover, 194 pages
1st Edition, published 2009 by Springer Science + Business Media, New York