By Sam Sim
This book takes a ground-breaking approach in explaining transfer pricing in a logical, clear and easy-to-understand way with liberal use of diagrams and practical illustrations. The issue of transfer pricing has put companies with global presence like Starbucks, Google and Apple in the news.
Whether you are a CFO or financial controller with transfer pricing impacting your statutory accounts, a tax leader managing transfer pricing risk or a finance manager wrestling with transfer pricing true-ups, you will find this book to be an accessible and indispensable companion.
The key features of this book include:
- Making sense of BEPS (Base Erosion and Profit Shifting) including the latest September 2014 Action 8 on Intangibles and Action 13 Country by Country Reporting
- User-friendly layout, diagrams and illustrations
- Logical sequence and exposition of key concepts using plain English
- Practical dimensions - strategy, planning, dispute resolution, operational TP, operating in developing countries and organising a transfer pricing function
- Transfer pricing presenting in a multidisciplinary context across tax, law, economics and accounting
What you will not find in this book:
- Hard to understand legal ‘mumbo'jumbo'
- Meaningless ‘cut-and-paste' of entire chapters from OECD transfer pricing guidelines or legislation
- ‘Space fillers' of individual country rules and regulations
This style of writing is borne out of the author's experience as a Deputy Head of Global Transfer Pricing of a FTSE100 multinational company and finessed through lecturing at the IBFD Academy and to CPAs and Master of Tax candidates.
Part I - The Core
1. The Intuition behind Tax Transfer Pricing
2. The OECD Approach
3. The Arm's Length Principle
4. Applying the Arm's Length Principle: Comparability Analysis
5. Pulling it Together
Part II - Key Areas of Transfer Pricing and Base Erosion & Profit Shifting ('BEPS')
7. Intra-Group Service Charges
8. The G20-OECD Initiative Against BEPS
9. Special Considerations for Intangilbles
10. Business Restructuring
11. Permanent Establishment and the authorised OECD Approach
Part III - Transfer Pricing in Motion: Practical Perspectives from Implementing Transfer Pricing
12. Audit & Dispute Resolution
13. Transfer Pricing in Practical Context
14. Developing the In-house Transfer Pricing Capability
15. Practising Transfer Pricing in Non-OECD Developing Countries