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The Logic and Practice of Transfer Pricing [eBook]
Author :
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.
Publication Date: January 2016
Publisher: LexisNexis
Key FeaturesThis 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.Includes:♦ Making sense of BEPS ( Base Erosion and Profit Sifting) including the latest September 2014 Action 8 on intangibles and Action 13 on 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 presented in a multidisciplinary context across tax, law, economics and accounting
VOLUME I
Chapter 1: Framework of Interpretation in Tax
Chapter 2: Analysing Tax Decisions "New"
Chapter 3: Negligence in Tax "New"
Chapter 4: Ethics in Taxation "New"
Chapter 5: Case Law Guidance on Source of Business and Trade Income
Chapter 6: Receipts
Chapter 7: Exemptions "New"
Chapter 8: Expenditures
Chapter 9: Relevance of Accountancy Principles and Practices in Taxation
Chapter 10: Interest Expense Disallowance Formula "New"
Chapter 11: Compensations "New"
Chapter 12: Capital Allowances
Chapter 13: Losses and Unabsorbed Allowances "New"
Chapter 14: Group Relief "New"
Chapter 15: Withholding Tax and Taxation of Non-Residents
Chapter 16: EEIA Tax Incentives "New"
Chapter 17: Taxation of Intellectual Properties
Chapter 18: Corporate Restructuring, Mergers and Acquisitions
Chapter 19: Capital Market Transactions
Chapter 20: Taxation of Hedge Funds and Private Equity Firms
Chapter 21: Unit Trusts
VOLUME II
Chapter 22: Sea Transportation "New"
Chapter 23: Air Transportation "New"
Chapter 24: Telecommunications "New"
Chapter 25: Banking Operations
Chapter 26: Insurance Operations
Chapter 27: Financial Derivatives
Chapter 28: Clubs and Trade Associations "New"
Chapter 29: Partnership "New"
Chapter 30: Source of Employment Income and Some Related Taxation Issues
Chapter 31: Taxation of Employment Income"New"
Chapter 32: Employee Stock Options and Share Schemes
Chapter 33: Tax Factors in Wealth Management for Individuals
Chapter 34: Income from Estates and Trusts "New"
Chapter 35: Corporate Residence "New"
Chapter 36: Some Issues in Tax Planning "New"
Chapter 37: Tax Treaties and Treaty Interpretation
Chapter 38: Sovereign Immunity and the Extra-Territorial Enforcement of Tax "New"
Chapter 39: Providing Tax Certainty: Theory and Practice of Ruling Applications "New"
Chapter 40: The Limits of the Comptroller's Discretion under the Income Tax Act "New"
Chapter 41: About Tax Controversy - Facts, Evidence and Tax Risk Management "New"
Chapter 41A: Facts and Evidence "New"
Chapter 41B: Tax Risk Management "New"
Chapter 42: Practical Aspects of and Best Practices in Transfer Pricing"New"
Chapter 43: Controversies in Transfer Pricing - A Survey of Significant Case Law Decisions Globally
Chapter 44: Tax Effective Supply Chain Management "New"
Chapter 45: Tax Avoidance
Chapter 46: Issues in Tax Investigations and Tax Audits
Chapter 47: Income Tax Objections and Appeals
Chapter 48: Taxation and Non-Taxation Measures for Sustainable Development in Singapore