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Global Transfer Pricing: Principles and Practice, 4th edition

Global Transfer Pricing: Principles and Practice, 4th edition

written by John Henshall
£120.00
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Introduction: In recent years, transfer pricing has become a key feature of tax management for multinationals and tax authorities alike. Global Transfer Pricing: Principles and Practice (4th edition) provides a straightforward introduction to this complex area, offering an overall understanding of transfer pricing as it is practised today.
Category: International
Publisher: Bloomsbury Professional
Publication Date: July 2019
ISBN: 9781526511218
Description: The previous edition was published shortly after the end of the OECD BEPS recommendation phase had finished and we are now well into the implementation phase, with much follow-up work having been done on the original Actions. Therefore this new edition will include:
- an update on implementation of BEPS recommendations, including artificial avoidance of permanent establishment status and prevention of treaty abuse
- implementation of transfer pricing documentation and country-by-country reporting
- multilateral instrument implementation.
In particular:
- Chapter 5 ‘Types of Transaction: Financing’ will be updated to include commentary on the OECD discussion draft on transfer pricing aspects of financial transactions, including treasury function, guarantee fees and captive insurance
- Chapter 7 will be expanded to cover new guidance on profit split and the recent trend towards profit split in HMRC enquiries
- The ‘UK’ chapter will include new content on interest restriction rules and transfer pricing, penalties for non-compliance, rules governing the conduct of transfer pricing audits and also Brexit considerations
- A new chapter will be added on the ‘Allocation of profits to branches’ to cover Articles 7 and 9 and work with Financial Services teams on Financial Services branches.
Legislation and case law:
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017)
Individual OECD BEPS Reports detailing revised guidance on the BEPS Action Plan, including the OECD/G20 Inclusive Framework on BEPS: Progress Report (July 2018)
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