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840910
Transfer Pricing
Description
Principles of International Tax Law (Transfer Pricing and Thin Cap rules) Mind Map on Transfer Pricing, created by floughnane on 07/05/2014.
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principles of international tax law
transfer pricing and thin cap rules
Mind Map by
floughnane
, updated more than 1 year ago
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Created by
floughnane
over 10 years ago
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Resource summary
Transfer Pricing
State Practices
US: (i) extensive guidelines. (ii) Best method rule. (iii) CPM widely used
UK: (i) follows OECD (ii) BEPS leader
Germany: (i) OECD Generally (ii) best method based on comparability (iii) limitation on TNMM
Brazil: (i) Does not follow OECD (ii) safe harbour rates (iii) may use secret comparables
DTCs
Art. 7 Branch apportionment
Art 9 Adjustments
Art 25 MAP for TP disputes / or EU Arbitration convention
Thin Cap.
State Practices
KVR summaries
DTCs
Approaches
Global Formulary Apportionment
(1) measuring income of MNC as a whole (2) useful in Federal States (3) Problem of partial adoption (4) common tax bases and apportionment factors
Arm's Length Principle
(1) Objective (2) widely accepted (3) absence of comparables (4) States optionality and resulting conflicts (5) documentation burden
History
Attachments:
Transfer Pricing Notes
1933 Carrol Report LoN 1935 Draft Conv. 1995-2013 TP Guidelines 2008 Attribution to PEs
APA's
Importance of: Without it MNCs could (more) easily manipulate prices to erode tax bases from higher tax jurisdictions to low
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