Transfer Pricing in a Post-BEPS World
EUCOTAX Series on European Taxation Volume 50
Transfer Pricing in a Post-BEPS World summarizes and analyses the main transfer pricing topics under the focus of the OECD’s Base Erosion and Profit Shifting (BEPS) project. The BEPS project promises to make effective inroads into the much criticized corporate tax strategy known as aggressive transfer pricing, whereby the profitability of subsidiaries in different jurisdictions is “managed” via mispricing with the intent of minimizing the corporation’s overall tax burden. Although the OECD BEPS project is an ongoing endeavor, its accomplishments to date and developing trends are discernible. This book, including contributions by outstanding and renowned transfer pricing experts both from practice and academia, analyzes these trends and proposes reforms which would ensure that transfer pricing outcomes are better aligned with economic activities and value creation, which achieves a more equitable distribution of profits among different countries.
The book is based on papers presented and discussed at the first Global Transfer Pricing Conference hosted in February 2016 by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business).
What’s in this book:
Each chapter is dedicated to specific sections of the OECD’s BEPS Action Plan. Among the topics and issues covered are the following:
- arm’s length principle and its ongoing development;
- allocation of risk and recharacterization;
- intangibles (both license model and cost contribution arrangements);
- interest deductions and intra-group financing;
- low value-adding services;
- commissionaire arrangements and low-risk distributors;
- attribution of profits to permanent establishments;
- documentation requirements (including country-by-country reporting).
This book publicizes and examines the results of a transfer pricing research project, allowing new materials and findings to be accessed by the general public for the first time. It presents selected crucial topics and issues related to transfer pricing in a post-BEPS world, together with some possible solutions to these issues, by combining an academic and a practical approach.
How this will help you:
This book presents an overview of crucial topics and issues related to transfer pricing in a post-BEPS world, thereby enabling the designing of BEPS-compliant and economically sound arm’s length transfer pricing systems. As the most up-to-date and thorough consideration of transfer pricing yet published, this book proves to be invaluable for all parties currently facing questions related to transfer pricing in a post-BEPS world, especially those in charge of finding an ideal answer to them: academics, practitioners (including in-house and advisory counsel), international organizations, CEOs and CFOs of multinational enterprises, and government officials who are tax and transfer pricing experts.
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Chapter 1 The Arm’s Length Principle: Between Legal Fiction and Economic Reality
Chapter 2 Risks Redefined in Transfer Pricing Post-BEPS
Chapter 3 Transfer Pricing Aspects of Intangibles: The License Model
J. Scott Wilkie
Chapter 4 Transfer Pricing Aspects of Intangibles: The Cost Contribution Arrangement Model
Chapter 5 Interest Deductions and Transfer Pricing Aspects of Intra-Group Financing
Chapter 6 Transfer Pricing Aspects of Low Value-Adding Services
Chapter 7 Commissionaire Arrangements/Low Risk Distributors and Attribution of Profits to Permanent Establishments
Chapter 8 Transfer Pricing and Documentation Requirements
Christian Kaeser & Sven Bremer