Overview
- First in depth analysis of transfer pricing with an interdisciplinary legal and economic approach
- Covers traditional approaches to transfer pricing (e.g. OECD) as well as alternative mechanisms for the allocation of taxing rights such as formulary apportionment
- Looks both at fundamental and practical questions of transferpricing
- Addresses key problems of transfer pricing in relation tointangibles, capital and risk allocation
- Includes supplementary material: sn.pub/extras
Part of the book series: MPI Studies in Tax Law and Public Finance (MPISTUD, volume 1)
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Table of contents (14 chapters)
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Front Matter
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The Roles and Functions of Transfer Pricing in Organisations
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Front Matter
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The OECD Approach to Transfer Pricing
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Front Matter
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Transfer Pricing in Practice
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Front Matter
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Separate Accounting, Profit Split and Formulary Apportionment
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Front Matter
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Separate Accounting, Profit Split and Formulary Apportionment
Keywords
About this book
The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure.
Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights.
With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Editors and Affiliations
Bibliographic Information
Book Title: Fundamentals of International Transfer Pricing in Law and Economics
Editors: Wolfgang Schön, Kai A. Konrad
Series Title: MPI Studies in Tax Law and Public Finance
DOI: https://doi.org/10.1007/978-3-642-25980-7
Publisher: Springer Berlin, Heidelberg
eBook Packages: Humanities, Social Sciences and Law, Law and Criminology (R0)
Copyright Information: Springer-Verlag Berlin Heidelberg 2012
Hardcover ISBN: 978-3-642-25979-1Published: 16 February 2012
Softcover ISBN: 978-3-642-43428-0Published: 13 April 2014
eBook ISBN: 978-3-642-25980-7Published: 15 February 2012
Series ISSN: 2196-0011
Series E-ISSN: 2196-002X
Edition Number: 1
Number of Pages: XIV, 306
Topics: International Economic Law, Trade Law, Public Economics, Private International Law, International & Foreign Law, Comparative Law, Law and Economics