Transfer Pricing and Corporate Taxation

Problems, Practical Implications and Proposed Solutions

Authors: King, Elizabeth

  • Discusses economic issues underlying existing methods and proposes alternatives
  • Detailed analysis of case studies drawn on the author’s professional experience
  • Enables professionals in companies to perform transfer pricing analyses
  • Incorporates the new US services regulations issued in July 2006 and the new cost-sharing regulation expected to be published in late 2007 or early 2008
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eBook $109.00
price for USA (gross)
  • ISBN 978-0-387-78183-9
  • Digitally watermarked, DRM-free
  • Included format: PDF
  • ebooks can be used on all reading devices
  • Immediate eBook download after purchase
Hardcover $139.00
price for USA
  • ISBN 978-0-387-78182-2
  • Free shipping for individuals worldwide
  • Usually dispatched within 3 to 5 business days.
Softcover $139.00
price for USA
  • ISBN 978-1-4419-2678-4
  • Free shipping for individuals worldwide
  • Usually dispatched within 3 to 5 business days.
About this book

Transfer pricing is often identified as the most important tax issue that multinational corporations face. This publication is an extremely useful tool for practitioners and tax directors grappling with complex and contentious transfer pricing issues of various kinds. It contains a series of highly detailed case studies, which draw on the author's two decades as a government economist specializing in transfer pricing and valuation, a transfer pricing economist with Price Waterhouse, and, lastly, an independent consultant. These case studies elucidate the types of intercompany transactions that tax authorities often scrutinize, lay out how one should go about analyzing such transactions under the existing regulatory regime in considerable detail, and illustrate a number of proposed alternative approaches that could substantially reduce compliance costs and the frequency of transfer pricing disputes.

Practitioners and tax directors will find the case studies extremely helpful in formulating defensible transfer pricing policies. The case studies may also be useful in assessing tax exposure attributable to intercompany pricing practices, as required under FASB Interpretation No. 48 (FIN 48). Tax policy analysts will find the evaluation and critique of existing methods and the development of alternative proposals thought-provoking and compelling.

The book is divided into three parts: Part I contains a detailed review and critique of individual transfer pricing methods and the economic premises that underpin them. Part II contains a discussion of proposed alternative transfer pricing methods. Part III contains the aforementioned series of eight case studies, encompassing a broad range of transfer pricing issues. Global trading and certain types of Internet-based businesses, which the current transfer pricing regime does not adequately address, are among the issues covered. Each case study is analyzed under both the existing transfer pricing regime and one or more proposed methods.

Reviews

From the reviews:

“The book of Elizabeth King is written for the benefit of tax practitioners. The focus is on the various transfer pricing cases. The case studies reflect in particular the US views as for example the FIN 48 specifications. We recommend this book to tax advisors and inhouse tax specialists handling transfer pricing aspects in particular related to the US.” (Steuern-buecher, September, 2012)


Table of contents (13 chapters)

  • Introduction

    King, Elizabeth

    Pages 1-4

  • Economic vs. Accounting Profit Rates

    King, Elizabeth

    Pages 7-10

  • Overview and Critique of Existing Transfer Pricing Methods

    King, Elizabeth

    Pages 11-48

  • Some Alternative Approaches to Transfer Pricing

    King, Elizabeth

    Pages 51-64

  • Intercompany Sale of Diamonds

    King, Elizabeth

    Pages 67-88

Buy this book

eBook $109.00
price for USA (gross)
  • ISBN 978-0-387-78183-9
  • Digitally watermarked, DRM-free
  • Included format: PDF
  • ebooks can be used on all reading devices
  • Immediate eBook download after purchase
Hardcover $139.00
price for USA
  • ISBN 978-0-387-78182-2
  • Free shipping for individuals worldwide
  • Usually dispatched within 3 to 5 business days.
Softcover $139.00
price for USA
  • ISBN 978-1-4419-2678-4
  • Free shipping for individuals worldwide
  • Usually dispatched within 3 to 5 business days.
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Bibliographic Information

Bibliographic Information
Book Title
Transfer Pricing and Corporate Taxation
Book Subtitle
Problems, Practical Implications and Proposed Solutions
Authors
Copyright
2009
Publisher
Springer-Verlag New York
Copyright Holder
Springer-Verlag New York
eBook ISBN
978-0-387-78183-9
DOI
10.1007/978-0-387-78183-9
Hardcover ISBN
978-0-387-78182-2
Softcover ISBN
978-1-4419-2678-4
Edition Number
1
Number of Pages
XIV, 194
Topics