Fundamentals of Transfer Pricing

Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint 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), the international tax law firm L&P - Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment.For the purpose of easy understanding, the book is presented in two parts:Part I: General TopicsI. Introduction to Transfer PricingII. Accurate Delineation and Recognition of Actual Transactions: Comparability AnalysisIII. Transfer Pricing Methods (Part I): Traditional Transaction MethodsIV. Transfer Pricing Methods (Part II): Transactional Profit MethodsV. Administrative Approaches to Avoiding/Minimizing Transfer Pricing DisputesVI. Administrative Approaches to Resolving Transfer Pricing DisputesVII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country ReportingPart II: Specific TopicsVIII. Attribution of Profits to Permanent EstablishmentsIX. Transfer Pricing and Intra-group ServicesX. Transfer Pricing and Intra-group Financial TransactionsXI. Transfer Pricing and IntangiblesXII. Transfer Pricing, Supply Chain Management and Business RestructuringsXIII. Transfer Pricing and Customs ValuationXIV. Transfer Pricing and EU State AidIn analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding.The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.