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Transfer Pricing Aspects of Intra-Group Financing provides one of the first in-depth analyses of the current worldwide working of transfer pricing in intra-group financing, and its resonance in law. For corporate managers, maximization of profits and market value of the company are prime objectives. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally because of the very attractive tax advantages obtainable. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This book presents solutions to issues that are related to transfer pricing and intra-group financing, by combining an academic and a practical approach.This important book presents the relevant issues related to loans, financial guarantees, and cash pooling and analyses an innovative possible approach to these issues. The book also describes new methodologies that can be implemented in practice, in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle.

vennootschapsbelasting --- oecd --- transfer pricing --- impot des societes

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Long description: The Major Developments in Tax Policy Steadily increasing globalization as well as the financial and economic crisis have brought major challenges for states in ensuring budgetary consolidation while maintaining sustainable economic growth. These developments have not only influenced political and economic discussions in the 21st century, but also raise new questions on the role of taxation in the economic policy environment. National taxation systems worldwide are subject to significant changes and it is assumed that they will develop in a more co-operative way in the near future. This book aims at identifying the major developments in tax policy in the 21st century on a national as well as on an international level and gives an in-depth analysis of the challenges and risks, but also of the opportunities connected to these developments. Ist covers numerous and discrete issues ranging from challenges in the VAT/GST area, the taxation of the financial sector, the fight against aggressive tax planning, tax abuse and tax evasion, tax integration within the EU, the development of transfer pricing rules, the increasing role of co-operative compliance and good governance and the changing tax policies of developing and newly industrialized countries. The contributions in this book build upon a legal comparison of the national tax systems in the relevant fields, propose tax policy solutions where required and give ideas on how to go forward. Long description: The Major Developments in Tax Policy Steadily increasing globalization as well as the financial and economic crisis have brought major challenges for states in ensuring budgetary consolidation while maintaining sustainable economic growth. These developments have not only influenced political and economic discussions in the 21st century, but also raise new questions on the role of taxation in the economic policy environment. National taxation systems worldwide are subject to significant changes and it is assumed that they will develop in a more co-operative way in the near future. This book aims at identifying the major developments in tax policy in the 21st century on a national as well as on an international level and gives an in-depth analysis of the challenges and risks, but also of the opportunities connected to these developments. Ist covers numerous and discrete issues ranging from challenges in the VAT/GST area, the taxation of the financial sector, the fight against aggressive tax planning, tax abuse and tax evasion, tax integration within the EU, the development of transfer pricing rules, the increasing role of co-operative compliance and good governance and the changing tax policies of developing and newly industrialized countries. The contributions in this book build upon a legal comparison of the national tax systems in the relevant fields, propose tax policy solutions where required and give ideas on how to go forward.

Taxation --- Comparative law --- Droit fiscal international --- Droit fiscal --- Droit comparé --- Law and legislation. --- Law and legislation --- Taxation - Law and legislation --- Internationales Steuerrecht --- Tax Treaty Law --- tax reform --- Tax Policy

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This publication covers various issues related to business restructuring, including delineation and recognition, remuneration of restructuring and post-restructuring, and other relevant issues such as exit taxes, location savings, permanent establishments, and implications of COVID-19.(source: publisher's website)

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Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with a far-reaching impact on countries' legislations, administrative guidelines, and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised.Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics:Global Transfer Pricing Developments.Transfer Pricing Developments in the European Union.Transfer Pricing Developments in the United States.Transfer Pricing Developments in Developing Countries and Emerging Economies.Recent Developments on Transfer Pricing in the Post-Covid-19 Era.Recent Developments on Transfer Pricing and Substance.Recent Developments on Transfer Pricing and Business Restructurings.Recent Developments on Transfer Pricing and New Technologies.The intense work of international organizations such as the OECD, UN, and other international organizations, as well as the intense work of the EU, is thoroughly analyzed in this book.The detailed analysis will be of immeasurable value to the various players, including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel, and interested academics in facilitating efficient dialog and a coordinated approach to transfer pricing in the future.

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