Transfer pricing : OECD transfer pricing guidelines /
"... describes, on a chapter by chapter basis, the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations of the Organisation for Economic Co-operation and Development (OECD). The authors incorporate into their approach historical and conceptual, as well as technical,...
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| Corporate Author: | |
| Other Authors: | , , , |
| Format: | Online |
| Language: | English |
| Published: |
Arlington, VA :
Tax Management Inc.,
[2005]-
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| Series: | Tax management portfolios ;
6936 |
| Subjects: | |
| Online Access: | https://www.bloomberglaw.com/product/tax/citation/tm%206936 |
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| Summary: | "... describes, on a chapter by chapter basis, the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations of the Organisation for Economic Co-operation and Development (OECD). The authors incorporate into their approach historical and conceptual, as well as technical, analysis. The analysis is designed to prove useful to practitioners who seek to make maximum use of the guidelines in fashioning tax plans that will be defensible in examinations by tax authorities around the world, and also in defending taxpayers' positions where necessary. Emphasis is placed on the legal relationship between the guidelines and the national transfer pricing laws of the United States and other countries. Suggestions are offered at various points of ways in which the Guidelines might be clarified, particularly (but not exclusively) in their treatment of transfer pricing for intangibles, both in and outside the context of cost sharing arrangements. " |
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| Item Description: | Authors: Robert E. Culbertson, Michael C. Durst and David B. Bailey, <Oct. 4, 2007>-2015 Formerly published in Washington, D.C., 2005-2007 Published as Tax Management Portfolio 894, <Oct. 4, 2007>- |
| Physical Description: | 1 online resource |
| Publication Frequency: | Updated irregularly |
| Bibliography: | Includes bibliographical references |