Transfer Pricing Handbook: Guidance on the OECD Regulations [Hardcover]

A business that is not aware of all of its exposure to the tax policy of each country in which it does business may find itself paying more in taxes that the share of profit it generates. The Organisation for Economic Co-operation and Development (OECD) seeks to reduce the risk of business taxation in multiple countries. Transfer Pricing Handbook explores how countries can apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. It is the ultimate comprehensive guide for companies doing business globally.

• Helps companies properly price their goods and services for global markets
• Provides defenses for transfer pricing audits
• Provides standards for creating comparables that multijurisdictional tax administrations will accept
• Guides documentation requirements and timing issues

If you're doing business in more than one country, Transfer Pricing Handbook is a must-have, essential guide for simplifying OECD regulations for your global company.

Preface xvii

Part I: Basic Transfer Pricing Standards 1

Chapter 1: Introduction 3

Control 4

Tax Havens 5

Complexities 5

Chapter 2: Arms Length Principle 7

General Explanation of the Arms Length Principle 8

Formal Statement as to the Arms Length Principle 10

Comparability Considerations 11

Rationale behind the Arms Length Principle 11

Compensation Issues 12

Applying the Arms Length Principle to Contribution Analysis 13

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