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Guide To International Transfer Pricing, Sixth Edition

Guide To International Transfer Pricing, Sixth Edition

By Duff & Phelps


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In Guide to International Transfer Pricing, global practitioners address both the general issues that surround transfer pricing, including the Organisation for Economic Co-operation of Development’s (OECD) fifteen-item Base Erosion and Profit Shifting (BEPS) plan and the specific rules and issues that any company must concern itself with in various jurisdictions around the world. Tax authorities around the globe are increasingly scrutinizing the intercompany pricing practices of taxpayers and enacting rules and regulations to ensure an appropriate allocation of income among the various tax jurisdictions in which a multinational company operates. In addition, a growing number of tax authorities have established documentation requirements to demonstrate appropriate transfer pricing policies, with penalty provisions for non-compliance. Not only must a multinational company understand the different nuances in the transfer pricing laws and their practical interpretation in each local country, but it must also appreciate that by operating in jurisdictions with varying tax rates, transactional structures or intercompany pricing policies can impact the multinational’s global effective tax rate.

What’s in this book:

This guide is a collaboration of many transfer pricing experts from around the world with experience gained from assisting multinationals in implementing planning and compliance strategies, and their insights into dealing with local tax authorities. Key features of this book include:

  • overview of fundamental concepts applied in transfer pricing;
  • country-specific profiles that compare and contrast rules and real-world applications over multiple jurisdictions, including those likely to adopt BEPS; and
  • practical guidance and implementation, enabling the reader to execute a coordinated, cost-effective approach to global policies and documentation needs.

How this will help you:

This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters, covering domestic transfer pricing issues in a variety of key national jurisdictions. The primary objective of this book is to arm the constituents impacted by transfer pricing, including tax directors, legal counsel, accounting and operations personnel, CFOs and outside advisors, with the knowledge base and resources needed for effective transfer pricing decision-making.


Last Updated 09/01/2016
Product Line Wolters Kluwer Legal & Regulatory U.S.
ISBN 9789041169082
SKU 10059163-0001
Table of Contents



List of Abbreviations


CHAPTER 1 Overview/Best Practices

Michelle Johnson, Justin Radziewicz & Uday Singh

CHAPTER 2 OECD Transfer Pricing Guidelines

Andrew Cousins & Danny Beeton

CHAPTER 3 Argentina

Matías Federico Lozano & Cristian E. Rosso Alba

CHAPTER 4 Australia

Shannon Smit & Adriana Calderon

CHAPTER 5 Belgium

Natalie Reypens

CHAPTER 6 Brazil

Luís Rogério Farinelli, Cristiane M.S. Magalhães, Stephanie Makin & Amanda Alves Brandão.

CHAPTER 7 Canada

Jennifer Shulman


Glenn DeSouza

CHAPTER 9 France

Félicie Bonnet & Arnaud Le Boulanger

CHAPTER 10 Germany

Angelika Thies

CHAPTER 11 Ireland

Joe Duffy & Barry McGettrick

CHAPTER 12 Israel

Jonathan Lubick

CHAPTER 13 Italy

Marco Valdonio, Aurelio Massimiano & Mirko Severi

CHAPTER 14 Mexico

Yoshio Uehara & Gustavo Méndez

CHAPTER 15 The Netherlands

Rogier Sterk & Patrick van Oppen

CHAPTER 16 South Korea

Tae Yeon (TY) Nam, Jae Suk (JS) Park & Christopher Sung

CHAPTER 17 United Kingdom

Shiv Mahalingham

CHAPTER 18 United States

Jill Weise, Stefanie Perrella & Rod Koborsi


ANNEX I Transfer Pricing Rules Summary

ANNEX II Transfer Pricing Implementation Checklist

Table of Cases