TP Lecture week 10 – Comparability analysis Part I

ATL-Editor 18 April 2018

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Follow curriculum – Reading:

OECD TPG Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration July 2017

Chapter III: A1 to A4.2

Scope of Work for Guidance on the Transactional Profit Split Method, page 55

BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... More Actions 8-10 Final Report

Intangibles, Risks & Capital, High-Risk Transactions

http://www.oecd.org/ctp/beps-actions.htm

General ongoing reading as the courses advance, reading about 10 pages a week to gain an overview understanding:

An Overview of Transfer Pricing by IBFD

Start your Assignment 3 preparation now – start reading the EXTENSIVE DOCUMENTS: the pre-trial filing of Coca-cola to the US tax court, and the long list of supporting articles, and start summarizing the case using the principles in 1 Reading cases SSRN-id1160925 This may appear as a key exam question as well.

The coca-cola case pre-trial document and articles can be found here: http://iitfconnect.com/?p=675

Categories: Africa, FP News, Nigeria, SADC, South Africa, West Africa, Zambia

Tags: Courses, Transfer Pricing

ATL-Editor

S.Africa: Summary of the Davis Tax Committee’s BEPS Sub-committee General Report released December 2014

Summary of the Davis Tax Committee’s BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... More Sub-committee General Report released December 2014 by Peter Dachs of ENS Introduction This note provides a summary of

ATL-Editor 26 February 2015

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Understanding the Profit Split Method (PSM) in Transfer Pricing

The Profit Split Method in Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More is a crucial approach used to ensure that transactions between related companies are conducted at arm’s length, meaning at fair market value. This method is particularly useful in scenarios where transactions are highly integrated and cannot be evaluated separately.

Dr Daniel N Erasmus 8 July 2024

AFRICA: Sub-Saharan Africa and international arbitration – how does that work?

COMMENT Tax arbitration via new double tax treaties is on the increase. Hence, knowledge of international arbitration is important. Take a look at the following

ATL-Editor 29 August 2014

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Transfer Pricing course contents table of reading materials by lecture

TRANSFER PRICINGTransfer pricing is a fundamental concept in international taxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More that defines the pricing methods and rules applied to transactions between related entities within a

ATL-Editor 20 April 2018

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Cook Islands: FATCA’s impact – this paper applies to many other offshore centres

April/May 2015[1] Impact of FATCA on Cook Islands Entities[2] TABLE OF CONTENTS Background The key differences between FATCA and IGA Models 1 and 2

ATL-Editor 27 April 2015

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