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Mind map

Transfer Pricing

floughnane Principles of International Tax Law English

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Transfer Pricing

  1. 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
  2. DTCs

    • Art. 7 Branch apportionment
    • Art 9 Adjustments
    • Art 25 MAP for TP disputes / or EU Arbitration convention
  3. Thin Cap.

    • State Practices
      • KVR summaries
    • DTCs
  4. 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
  5. History

    • 1933 Carrol Report LoN 1935 Draft Conv. 1995-2013 TP Guidelines 2008 Attribution to PEs
  6. APA's

  7. Importance of: Without it MNCs could (more) easily manipulate prices to erode tax bases from higher tax jurisdictions to low

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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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