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Transfer Pricing Handbook Guidance on the OECD Regulations

9781118347614

Transfer Pricing Handbook Guidance on the OECD Regulations

  • ISBN 13:

    9781118347614

  • ISBN 10:

    1118347617

  • Edition: 1st
  • Format: Hardcover
  • Copyright: 09/11/2012
  • Publisher: Wiley

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Summary

This book provides explanations of how countries apply the OECD Guidelines to tax businesses that conduct their endeavors in more than one country. Businesses have many facets. It is these facets that expose them to multiple taxation. For example, such a business may divide the manufacturing of its products between two countries, assemble the product in a third country, sell the product in countries four and five, and guarantee or fix any defective product in a sixth country. All six countries have an interest in taxing the share of profits attributable to the work or services done within its borders. A business that is not aware of all of its exposure to each country's taxing policy may find itself paying more in taxes that the share of profit it generates. The OECD seeks to reduce the risk of business taxation in multiple countries. It is in the interests of businesses to know what the worldwide Guidelines are, and to what point these Guidelines might differ from country to country so as to plan for the least amount of taxes a country can impose. The book is a comprehensive guide for companies doing business globally; a guide for companies to 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; and creates awareness against inadvertently becoming a permanent establishment..

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