Former subtitle: OECD transfer pricing rules and guidelines
1 online resource.
Tax management portfolios ; 6936.
"... describes, on a chapter by chapter basis, the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations of the Organisation for Economic Co-operation and Development (OECD). The authors incorporate into their approach historical and conceptual, as well as technical, analysis. The analysis is designed to prove useful to practitioners who seek to make maximum use of the guidelines in fashioning tax plans that will be defensible in examinations by tax authorities around the world, and also in defending taxpayers' positions where necessary. Emphasis is placed on the legal relationship between the guidelines and the national transfer pricing laws of the United States and other countries. Suggestions are offered at various points of ways in which the Guidelines might be clarified, particularly (but not exclusively) in their treatment of transfer pricing for intangibles, both in and outside the context of cost sharing arrangements. "
Authors: Robert E. Culbertson, Michael C. Durst and David B. Bailey, -2015. Formerly published in Washington, D.C., 2005-2007. Published as Tax Management Portfolio 894, -
Bibliography, etc. Note
Includes bibliographical references.
Formatted Contents Note
Detailed analysis. Introduction Chapter I of the Guidelines: The Arm's-Length Principle Chapter II: Transfer Pricing Methods Chapter III: Comparability Analysis Chapter IV: Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes Chapter V: Documentation Chapter VI: Special Considerations for Intangible Property Chapter VII: Special Considerations for Intra-Group Services Chapter VIII: Cost Contribution Arrangements Chapter IX: Transfer Pricing Aspects of Business Restructurings Working Papers.
Digital File Characteristics
Source of Description
Description based on contents viewed on Oct. 2, 2015; title from description page.
Available in Other Form
Print version: Chip, William W. Transfer pricing. Arlington, VA : Tax Management Inc., -