Overview
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.
Full Product Details
Author: Elizabeth King
Publisher: Springer-Verlag New York Inc.
Imprint: Springer-Verlag New York Inc.
Edition: Softcover reprint of hardcover 1st ed. 2009
Dimensions:
Width: 15.50cm
, Height: 1.10cm
, Length: 23.50cm
Weight: 0.454kg
ISBN: 9781441926784
ISBN 10: 144192678
Pages: 194
Publication Date: 29 October 2010
Audience:
Professional and scholarly
,
Professional & Vocational
Format: Paperback
Publisher's Status: Active
Availability: Out of print, replaced by POD
We will order this item for you from a manufatured on demand supplier.
Reviews
From the reviews: The book of Elizabeth King is written for the benefit of tax practitioners. The focus is on the various transfer pricing cases. The case studies reflect in particular the US views as for example the FIN 48 specifications. We recommend this book to tax advisors and inhouse tax specialists handling transfer pricing aspects in particular related to the US. (Steuern-buecher, September, 2012)
