Global Transfer Pricing: Principles and Practice

Now in its fourth edition, Global Transfer Pricing: Principles and Practices continues to provide a straightforward and accessible introduction to this complex and increasingly important area of business taxation.It offers readers an overall view of transfer pricing as it is practised today, including the 2017 changes to OECD transfer pricing guidance following the Base Erosion and Profit Shifting (BEPS) initiative. In addition to the theory of transfer pricing, this practical handbook explains how to implement transfer pricing models in global multinationals, how to monitor transactions to ensure compliance and how to create transfer pricing documentation.This new edition includes: -An update on the implementation of BEPS recommendations, including artificial avoidance or permanent establishment status and prevention of treaty abuse-Implementation of transfer pricing documentation and country-by-country reporting-Additional case law references Chapter updates include: -Chapter 5 'Financing' has been updated to include commentary on the OECD discussion draft on transfer pricing aspects of financial transactions, including treasury function, guarantee fees and captive insurance-Chapter 7 'Profit Split' has been expanded to cover new guidance on profit split and the recent trend towards the use of this transfer pricing methodology-The 'UK' chapter includes new content on interest restriction rules and transfer pricing, penalties for non-compliance, rules governing the conduct of transfer pricing audits and also Brexit considerations-A new chapter has been added on 'The Attribution of Profits to Permanent Establishments' to cover Articles 7 and 9 of the OECD Model Tax Treaty