Transfer Pricing and Business Restructurings
Transfer Pricing and Business Restructurings provides readers with an understanding of the key tax and transfer pricing concepts, methodologies and trends relating to business restructurings.
Why this book?
Business restructurings are a reaction to global competitive pressures and changing market demand. In response to market forces, multinational enterprises (MNEs) may be able to retain their profit margins only by undertaking a restructuring.
By drawing together divergent views Transfer Pricing and Business Restructurings highlights the main tax issues that arise when business restructurings take place. It provides fundamental information about the drivers of business restructurings and business models, examines the application of Art. 9 of the OECD Model Convention and considers not only the direct tax issues in business restructuring, but also VAT and customs duties
The book also gives practical insights into the tax accounting treatment of business restructurings, OECD work in progress and the effect of the EU tax system. And includes a case study concerning the restructuring of a manufacturing operation, which is analysed from the perspective of key industrial jurisdictions, along with an examination of current practice.
Countries/Jurisdictions covered:
China, Germany, India, Switzerland, United Kingdom and United States.
Transfer Pricing and Business Restructurings
DOI: https://doi.org/10.59403/6c2peh
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Acknowledgements
DOI: https://doi.org/10.59403/6c2peh002
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Abbreviations and Common References
DOI: https://doi.org/10.59403/6c2peh003
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Chapter 1 – Introduction
DOI: https://doi.org/10.59403/6c2peh004
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Chapter 2 – Business Models
DOI: https://doi.org/10.59403/6c2peh005
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Chapter 3 – OECD Policy Framework
DOI: https://doi.org/10.59403/6c2peh006
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Chapter 4 – EU Policy Framework
DOI: https://doi.org/10.59403/6c2peh007
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Chapter 5 – Art. 9 of the OECD Model Convention
DOI: https://doi.org/10.59403/6c2peh008
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Chapter 6 – Permanent Establishment Issues
DOI: https://doi.org/10.59403/6c2peh009
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Chapter 7 – VAT Aspects of Business Restructuring
DOI: https://doi.org/10.59403/6c2peh010
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Chapter 8 – Customs Duties
DOI: https://doi.org/10.59403/6c2peh011
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Chapter 9 – Tax Accounting Considerations
DOI: https://doi.org/10.59403/6c2peh012
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Chapter 10 – China
DOI: https://doi.org/10.59403/6c2peh013
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Chapter 11 – Germany
DOI: https://doi.org/10.59403/6c2peh014
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Chapter 12 – India
DOI: https://doi.org/10.59403/6c2peh015
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Chapter 13 – Switzerland
DOI: https://doi.org/10.59403/6c2peh016
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Chapter 14 – United Kingdom
DOI: https://doi.org/10.59403/6c2peh017
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Chapter 15 – United States
DOI: https://doi.org/10.59403/6c2peh018
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Chapter 16 – Case Study
DOI: https://doi.org/10.59403/6c2peh019
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Chapter 17 – Conclusion
DOI: https://doi.org/10.59403/6c2peh020
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Valerie Amerkhail, Anuschka Bakker, George Bradt, Irene J.J. Burgers, Mukesh Butani, Andrew Casley, Koen De Grave, Monica Erasmus-Koen, Massimo Fabio, Alan W. Granwell, Monique van Herksen, Nadine Hiller, Heinz-Klaus Kroppen, Patrick Mathieu, Jennifer Moore, René van der Paardt, Achim Roeder, Richard Schmidtke, Jonathan Schwarz, Caroline Silberztein, Werner Stuffer, Ynze van der Tempel, Chris Tierney, Steven Tseng, Nele Vandervelden and Markus Wyss.
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