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Transfer Pricing and Corporate Taxation - Problems, Practical Implications and Proposed Solutions (Hardcover, 2009 ed.)
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Transfer Pricing and Corporate Taxation - Problems, Practical Implications and Proposed Solutions (Hardcover, 2009 ed.)
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National tax authorities individually determine multinational ?rms'
country-speci?c tax liabilities by applying one or more sanctioned
transfer pricing methodologies. These methodologies are founded on
basic assumptions about market structure and ?rm behavior that are
rarely empirically valid. Moreover, for the most part, the transfer
pricing methodologies now in vogue were developed before the
Internet became a dominant factor in the world economy, and hedge
and private equity funds transformed ?nancial and commodities
markets. For these reasons, multinational ?rms are unable to
accurately anticipate their tax liabilities in individual
countries, and remain at risk of double taxation. Uncertainties in
corporate tax liability are extremely costly, both for individual
corporations and from an economy-wide perspective. Firms pay
exorbitant fees to have tax attorneys, accountants and economists
prepare the documentation required by tax authorities to
substantiate their intercompany pricing practices and defend their
tax positions on audit. Corporate tax liabilities are also
potentially much higher than they would be under a more transparent
and predictable transfer pricing regime (due to the potential for
double taxation and penalties), and investors' returns are reduced
accordingly. The FASB's Interpretation No. 48, Accounting for
Uncertainty in Income Taxes (released on July 13, 2006), has
motivated multinational ?rms to increase their reserves
substantially (in many cases at the insistence of their au- tors),
reducing the total funds available for productive investment. 1 The
current transfer pricing regimes are embodied in the OECD
Guidelines, individual OECD member countries' interpretations
thereof, the U. S.
General
Imprint: |
Springer-Verlag New York
|
Country of origin: |
United States |
Release date: |
October 2008 |
First published: |
2009 |
Authors: |
Elizabeth King
|
Dimensions: |
235 x 156 x 19mm (L x W x T) |
Format: |
Hardcover
|
Pages: |
194 |
Edition: |
2009 ed. |
ISBN-13: |
978-0-387-78182-2 |
Categories: |
Books >
Business & Economics >
Finance & accounting >
Accounting >
General
|
LSN: |
0-387-78182-X |
Barcode: |
9780387781822 |
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