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Transfer Pricing Risks Post-BEPS: A Practical Guide
Author
:
Anil Hargovan
Transfer Pricing Risks Post-BEPS: A Practical Guide explores the issues raised by the BEPS project and offers the readers a practical approach to risk assessment and mitigation in preparation for new legislation and rules to come.
Publication Date: December 2017
Publisher: LexisNexis Butterworths
Transfer pricing has never had as much media exposure as last year and keeps showing up on the headlines of all major newspapers and other media. Political pressure and the increasing government deficit that is affecting most of the countries are putting a lot of pressure on tax authorities worldwide to fill in the budget gap and are driving a more aggressive and inquisitive approach towards tax payers. The OECD embarked on a very difficult mission with its Base Erosion and Profit Shifting ("BEPS") project, which started with the G20 in 2012. The world of Transfer Pricing as we know it is changing as the BEPS project continues to raise new issues with the existing structures setup by large multinational and often driven by the desire to achieve better tax efficiency. Although, the BEPS project is well advanced, only few countries have already issued new legislation and amendments to transfer pricing regulations to comply with the new principles from the BEPS project.
The lack of clarity on how BEPS will translate in all the different jurisdictions is a concern for not just tax directors, but also CEOs and CFOs. Transfer Pricing Risks Post-BEPS: A Practical Guide explores the issues raised by the BEPS project and offers the readers a practical approach to risk assessment and mitigation in preparation for new legislation and rules to come. The readers are also guided through how supply chain planning is likely to change in the future and how businesses can still ensure their vision and strategy can be implemented whilst minimising risk and improving efficiencies that go hand in hand with real commercial planning.
Part One: Introduction, Background and General Principles
1. Child Protection in England and Wales
2. The Origins of the Present System
3. Fundamentals of the Children Act 1989
4. Other Orders
5. Jurisdiction
6. Human Rights Considerations
Part Two: Child Protection Measures Short of Care Proceedings
7. Local Authority Investigation, Support and Intervention
8. The Pre-Proceedings Process
9. The Decision to Commence Proceedings
Part Three: Emergency Intervention
10. Police Protection Orders
11. Emergency Protection Orders
Part Four: Care Proceedings: From Issue to Final Hearing
12. The Procedural Stages of an Application for a Care Order: An Overview
13. The Process of Issuing an Application and the Formal Requirements when doing so
14. Initial Case Management
15. Interim Care Orders: Interim Care Orders Part 1 - Interim Threshold
16. Interim Care Orders Part 2 - Welfare Decisions at the Interim Stage
17. Interim Care Orders Part 3 - Case Management of Interim Care Order Applications
18. Interim Care Orders Part 4 - The Interim Care Order
19. Appealing the Decision on an Interim Care Order Application
Part Five: Care Proceedings: Final Hearings and Final Orders
20. Preparation for the Final Hearing
21. The Final Hearing: Practical Considerations
22. Final Threshold
23. The Welfare Test for making a Final Care Order
24. Final Care Plans
25. The Effect of Making a Final Care Order
26. Appeals against Final Care Orders
Part Six: Alternatives to the making of a Final Care Order
27. Supervision Orders
28. Placement under a Child Arrangements Order
29. Special Guardianship Orders
Part Six: Adoption
30. The Nature of Adoption
31. Adoption: General Considerations
32. Adoption: Parental Consent and Placement Orders
33. Adoption: Appeals
Appendices