Transfer Pricing

This book presents the complex area of transfer pricing in a clear and structured way by means of a case study. The case study involves cross-border transactions of a fictive company group. Every chapter includes specific aspects relating to the initial case. The authors base the case-solving on OECD Transfer Pricing Guidelines for Multinational Enterprises with multiple references made to German tax law. It is the aim of the book to introduce beginners in to the basics of transfer prices for tax purposes. In principle everything could be reduced to a globally unified standard: the arm's length principle. The book grants the reader an entertaining, practical and structured introduction into the world of transfer pricing giving the necessary orientation and at the same time raising awareness which can also be supportive for advanced practitioners. Table of Contents:1. Introduction - the arm's length principle2. The first step: Value Chain Analysis3. Transfer Pricing Methods4. Comparability Analysis5. Supply of materials6. Intangibles7. Services8. Cost Sharing Arrangements9. Cost Contribution Arrangements10. Business restructuring/transfer of functions11. Financial Transactions12. Tax challenges arising from the digitalisation of the economy13. Permanent Establishments14. Obligation to cooperate - Transfer pricing documentation15. Country-by-Country Reporting16. Litigation, dispute avoidance and resolution