Raffaele Petruzzi, Transfer Pricing Aspects of Intra-Group Financing, Wolters Kluwer, 2016

Raffaele Petruzzi, Transfer Pricing Aspects of Intra-Group Financing, Wolters Kluwer, 2016

EUCOTAX Series on European Taxation Volume 47

Transfer Pricing Aspects of Intra-Group Financing provides one of the first in-depth analyses of the current worldwide working of transfer pricing in intra-group financing, and its resonance in law. For corporate managers, maximization of profits and market value of the company are prime objectives. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally because of the very attractive tax advantages obtainable. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This book presents solutions to issues that are related to transfer pricing and intra-group financing, by combining an academic and a practical approach.

This important book presents the relevant issues related to loans, financial guarantees, and cash pooling and analyses an innovative possible approach to these issues. The book also describes new methodologies that can be implemented in practice, in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle.

What’s in this book:

Comparing tax measures implemented in corporate tax law systems of forty countries, this study investigates aspects such as:

  • corporate finance theories, studies, and surveys regarding financing decisions;
  • application of the arm’s length principle to limit the deductibility of interest expenses;
  • impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project;
  • transfer pricing issues related to intra-group financing;
  • credit risk in corporate finance;
  • rationales utilized by credit rating agencies; and
  • the assessment of arm’s length nature of intra-group financing.

The author describes ways in which the application of the arm’s length principle can be strengthened, and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector.

How this will help you:

Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by the OECD Member States and their national courts is of great practical value in corporate decision-making.

 

ISBN: 9789041167323
Pages: 336
SKU: 9041167323
ETA: Available: Item ships in 3-5 Business Days

About the Author

Foreword

Preface

List of Abbreviations

List of Figures

List of Tables

Introduction

Chapter 1 Corporate Financing Decisions and Related Tax Issues

Chapter 2 Transfer Pricing Issues Related to Intra-Group Financing

Chapter 3 Assessing the Arm’s Length Nature of Intra-Group Financing: A New Approach

Conclusions

APPENDICES

APPENDIX I Debt Ratios (Median Values) of European Non-Financial Corporations in 2013

APPENDIX II Debt Ratios (Interquartile Values) of BB Rated European Non-Financial Corporations in 2013

Bibliography

Table of Cases, Rulings and Guidelines

Index

Lasă un răspuns

Te rog autentifică-te folosind una dintre aceste metode pentru a publica un comentariu:

Logo WordPress.com

Comentezi folosind contul tău WordPress.com. Dezautentificare / Schimbă )

Poză Twitter

Comentezi folosind contul tău Twitter. Dezautentificare / Schimbă )

Fotografie Facebook

Comentezi folosind contul tău Facebook. Dezautentificare / Schimbă )

Fotografie Google+

Comentezi folosind contul tău Google+. Dezautentificare / Schimbă )

Conectare la %s

%d blogeri au apreciat asta: