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Transfer Pricing and Intra-Group Financing

This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.

 

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Title:

Transfer Pricing and Intra-Group Financing

Editor(s):
Anuschka Bakker, Marc M. Levey
Date of publication:
ISBN:

978-90-8722-152-2

Type of publication:

Print Book

Number of pages:

592

Terms:

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Price:
EUR 120 / USD 150 (VAT excl.)
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Title:

Transfer Pricing and Intra-Group Financing

Editor(s):
Anuschka Bakker, Marc M. Levey
Date of publication:
ISBN:

978-90-8722-153-9

Type of publication:

eBook in ePub format

Number of pages:

592

Terms:

Please note: Adobe Digital Editions is required

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Price:
EUR 96 / USD 120 (VAT excl.)
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Title:

Transfer Pricing and Intra-Group Financing

Editor(s):
Anuschka Bakker, Marc M. Levey
Date of publication:
ISBN:

978-90-8722-152-2

Type of publication:

Online Book

Number of pages:

592

Access:

Up to five users. View purchase information

Price:
EUR 120 / USD 150 (VAT excl.)
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Transfer Pricing and Intra-Group Financing

Why this book?

Transfer Pricing and Intra-Group Financing is a practical guide that addresses the transfer pricing issues related to intra-group financing transactions. Currently, tax authorities and transfer pricing professionals are focusing on these transactions – and the application of the arm’s length principle. This growing attention is largely dictated by two factors: (i) the relative importance that financial transactions have in multinational groups and the significant amounts involved; and (ii) the increased awareness of tax authorities (and taxpayers alike) who, having for many years primarily dealt with transfer pricing issues related to goods and services, are now being confronted with the complexity of the pricing of these financial transactions. The so-called “credit crunch”, which began in late 2007 and in mid-2008 exploded on the financial services industry and the global economy, has also heavily influenced this field of application of the arm’s length principle. The impact of the financial markets on this area of transfer pricing continues today.
 
The book starts with an introductory chapter covering the financial markets, treasury functions, economic theory underlying financial transactions and the OECD framework regarding financial instruments. Country chapters detail not only the transfer pricing consequences of financial instruments (e.g. profit participating loans, guarantee fees, cash pooling, factoring, leasing) but also present ideas on how a transfer pricing policy could be constructed for these transactions. The increased likelihood of tax disputes resulting from intercompany financing arrangements reinforces taxpayers’ need to revisit existing arrangements and implement policies and procedures that are in line with the new market circumstances and the varying approaches to this issue. Tools to address, substantiate and price intercompany financial transactions are provided throughout the book. Furthermore, practical anecdotes, diagrams and tables are intertwined into the analysis to give the reader some working knowledge of transfer pricing issues related to intra-group financing.
 
This book is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax
directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and
intra-group financing.
 

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Editor(s)

Anuschka Bakker is Chief Editor Topicals of IBFD's Knowledge Centre, where she has overall responsibility for IBFD's publications on transfer pricing, permanent establishments, holding companies, mergers and acquisitions, and derivatives and financial instruments. Ms Bakker is both an avid writer and editor (Tax Risk Management, Transfer Pricing and Business Restructuring, Transfer Pricing and Customs Valuation, Transfer Pricing and Dispute Resolution). She is also involved in lecturing in the above-mentioned fields.

Marc M. Levey (Partner Baker & McKenzie, United States) is the past Chair of Baker & McKenzie's Global Transfer Pricing Steering Committee, and co-Chair of the Fashion and Luxury Goods Practice Group. With over 30 years of experience in international taxation, he is recognized as one of the world's leading tax advisers and transfer pricing experts. Mr Levey is the author of numerous publications and is a prolific speaker at international tax events worldwide.
 

Contributor(s)

Edgar Ahrens, Evelyne Bagdassarian, Paul Balkus, Fred Barrett, Marius van Blerck, Michel van der Breggen, Mukesh Butani, Mac Calva, Krishnan Chandrasekhar, Cheng Chi, Christophe Clément, Joe Duffy, Lorraine Eden, Nick Foster-Taylor, Mike Gaffney, Melissa Heath, Patrick Hendrix, Laura Hoyland, Naoya Kaneko, Justin Kutyan, Svetlana Kuzmina, Omar Moerer, Nobuo Mori, Marcelo Natale, Carlos Nicacio, Gibson Ng, Belema Obuoforibo, André Pesch, Achim Roeder, Antonio Russo, Pooja Samtani, Martin Schenk, Caroline Silberztein, Raoul Stocker, Richard G. Tremblay.
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