| Description |
1 online resource (xxiv, 363 pages) : illustrations |
| Series |
Directions in development. Public sector governance |
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Directions in development (Washington, D.C.). Public sector governance.
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| Contents |
880-01 Front Cover; Contents; Acknowledgments; Foreword; Introduction; Abbreviations; Chapter 1 Transfer Pricing, Corporate Strategy, and the Investment Climate; What Is Transfer Pricing?; Regulation of Transfer Pricing for Direct Taxation Purposes; Costs and Benefits of Regulating Transfer Pricing; Preconditions for Transfer Pricing Reform; Approaches to Transfer Pricing Regulation; Mitigating the Investment Climate Impact; Notes; Bibliography; Chapter 2 The International Legal Framework; Tax Treaties; Other International Instruments and Sources; Notes; Bibliography |
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880-01/(S Chapter 3 Drafting Transfer Pricing LegislationFormulating a "Transfer Pricing Policy"; Drafting Approach; Components of Transfer Pricing Legislation; Core Provisions; Practical Provisions; Administrative and Procedural Provisions; Role of Administrative Guidance; Practical Considerations when Drafting Transfer Pricing Legislation; Annex 3A: Transfer Pricing Legislation Checklist; Annex 3B:βExamples of "Relationships" from Selected Countries' Legislation; Annex 3C:βSelected Examples of Administrative Guidance on Transfer Pricing; Notes; Bibliography |
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Chapter 3 Drafting Transfer Pricing LegislationFormulating a "Transfer Pricing Policy"; Drafting Approach; Components of Transfer Pricing Legislation; Core Provisions; Practical Provisions; Administrative and Procedural Provisions; Role of Administrative Guidance; Practical Considerations when Drafting Transfer Pricing Legislation; Annex 3A: Transfer Pricing Legislation Checklist; Annex 3B: Examples of "Relationships" from Selected Countries' Legislation; Annex 3C: Selected Examples of Administrative Guidance on Transfer Pricing; Notes; Bibliography |
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Chapter 4 Applying the Arm's-Length PrincipleComparability; Transfer Pricing Methods; Selecting the Transfer Pricing Method; Selecting the Tested Party; Arm's-Length Range; Annex 4A: Sample Functional Analysis Questionnaire; Annex 4B: Examples of Commercial Databases Used for Transfer Pricing; Annex 4C: Example of Comparables Search Process; Annex 4D: Steps in the Comparability Analysis; Annex 4E: Comparability Adjustment Examples; Notes; Bibliography; Chapter 5 Selected Issues in Transfer Pricing; Intragroup Services; Financial Transactions; Intangibles; Cost Contribution Arrangements |
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Loss-Making Entities and Startup OperationsBusiness Restructurings; Location Savings; Government Regulation; Set-Offs; Transfer Pricing and Customs Valuations; Transfer Pricing and Value Added Tax; Attribution of Profits to Permanent Establishments; Notes; Bibliography; Chapter 6 Promoting Taxpayer Compliance through Communication, Disclosure Requirements, Transfer Pricing Documentation, and Penalties; Communication and Outreach; Disclosure Requirements: Collecting Information and Promoting Widespread Compliance; Transfer Pricing Documentation; Penalties Related to Transfer Pricing |
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Annex 6A: Overview of Information Collected through Transfer Pricing-Related DisclosuresAnnex 6B: Summary of Selected Countries' (Transfer Pricing) Disclosure Requirements; Annex 6C: Australia: Schedule 25A (2011)-Part A; Annex 6D: Denmark: Controlled Transactions Form; Annex 6E: Kenyan Revenue Authority: Disclosure of Transfer Pricing Transactions; Annex 6F: India: Form 3CEB (Transfer Pricing-Accountants Certificate); Annex 6G: New Zealand: Transfer Pricing Questionnaire (Foreign-Owned); Annex 6H: South Africa: Transfer Pricing Questionnaire (South African-Owned) |
| Summary |
Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country's potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm's length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country's tax base and raising additional revenue with investment climate considerations wherever appropriate |
| Bibliography |
Includes bibliographical references |
| Notes |
Resource, viewed March 6, 2017 |
| Subject |
Transfer pricing -- Developing countries -- Handbooks, manuals, etc
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BUSINESS & ECONOMICS -- Industrial Management.
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BUSINESS & ECONOMICS -- Management.
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BUSINESS & ECONOMICS -- Management Science.
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Transfer pricing
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Developing countries
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| Genre/Form |
handbooks.
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Handbooks and manuals
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Handbooks and manuals.
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Guides et manuels.
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| Form |
Electronic book
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| Author |
Fox, Randall
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Loeprick, Jan.
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Mohindra, Komal
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| LC no. |
2017385344 |
| ISBN |
9781464809705 |
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1464809704 |
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