This publication contains a series of highly detailed case studies, based on the author’s twenty-one years as a government economist specializing in transfer pricing and valuation, a transfer pricing economist with Price Waterhouse, and, lastly, an independent consultant. These case studies elucidate the typesof intercompany transactions that may be scrutinized by tax authorities, lay out how one should go about analyzing these transactions in painstaking detail, and suggest how one might assess tax exposure relating to transfer pricing. Tax policy analysts will find the evaluation and critique of existing methods and the development of alternative proposals thought-provoking and compelling.The book is split into two parts: The first part describes and critically analyses the transfer pricing methods and regulations currently in place and proposes alternative approaches. The second part consists of ten case studies Discusses economic underlyings of existing methods and proposes alternatives Detailed analysis of case studies drawn on the author’s professional experience Enables professionals in companies to perform transfer pricing analyses Incorporates the new US services regulations issued in July 2006 and the new cost-sharing regulation expected to be published late 2007/early 2008 INDICE: Introduction.- Economic vs. Accounting Profit Rates and Implications.- The Comparable Profits and Transactional Net Margin Method.- Resale Priceand Cost Plus Methods.- Comparable Uncontrolled Price Method.- Services Cost Method.- Profit Split Methods.- Cost-Sharing.- Proposed Alternative Approachesto Transfer Pricing.- Case Study 1.- Case Study 2.- Case Study 3.- Case Study4.- Case Study 5.- Case Study 6.- Case Study 7.- Case Study 8.- Case Study 9.- Case Study 10.- Conclusions.
- ISBN: 978-0-387-78182-2
- Editorial: Springer
- Encuadernacion: Cartoné
- Páginas: 225
- Fecha Publicación: 01/01/2009
- Nº Volúmenes: 1
- Idioma: Inglés