Covers the legislative and case law developments which have brought into question the compliance of the UK's transfer pricing rules with European Union (EU) law. Explores these issues in a style that is both comprehensive and informative, through the use of numerous practical examples and case studies.
Fundamental Sources; Selected Leading Cases; The Arm's Length Principle and Comparability; Associated Enterprises; Recharacterisation Issues; Functional Analysis; Analysis of Functions, Assets and Risk; Relating Functional Analysis to Selection of TP Method; Transfer Pricing Methods; Choice of TP Method; Comparability Analysis - OECD Proposed Process; Comparability Analysis Aggregation and Use of Non Third Party Transactions; Comparability Analysis - Sources of Information & Timing Issues; Comparability Adjustments; The Arm's Length Range; Comparability Compliance Issues; Specific Transactions: Intra-Group Services; Specific Transactions: Finance; Specific Transactions: IP; Specific Transactions: Business Restructuring; Permanent Establishments; Compliance Issues; Avoiding Double Taxation & Dispute Resolution; MAP
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Covers the legislative and case law developments which have brought into question the compliance of the UK's transfer pricing rules with European Union (EU) law. Explores these issues in a style that is both comprehensive and informative, through the use of numerous practical examples and case studies.
Fundamental Sources; Selected Leading Cases; The Arm's Length Principle and Comparability; Associated Enterprises; Recharacterisation Issues; Functional Analysis; Analysis of Functions, Assets and Risk; Relating Functional Analysis to Selection of TP Method; Transfer Pricing Methods; Choice of TP Method; Comparability Analysis - OECD Proposed Process; Comparability Analysis Aggregation and Use of Non Third Party Transactions; Comparability Analysis - Sources of Information & Timing Issues; Comparability Adjustments; The Arm's Length Range; Comparability Compliance Issues; Specific Transactions: Intra-Group Services; Specific Transactions: Finance; Specific Transactions: IP; Specific Transactions: Business Restructuring; Permanent Establishments; Compliance Issues; Avoiding Double Taxation & Dispute Resolution; MAP
Este título pertence ao(s) assunto(s) indicados(s). Para ver outros títulos clique no assunto desejado.