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The Resource Transfer pricing and dispute resolution : aligning strategy and execution, edited by Anuschka Bakker and Marc M. Levey

Transfer pricing and dispute resolution : aligning strategy and execution, edited by Anuschka Bakker and Marc M. Levey

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The item Transfer pricing and dispute resolution : aligning strategy and execution, edited by Anuschka Bakker and Marc M. Levey represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in Biddle Law Library - University of Pennsylvania Law School.
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Summary: ""Transfer pricing" relates to the pricing of transactions between related persons. The term is employed, however, not merely in reference to the existence of prices for those transactions but, more specifically, with regard to the control of those prices for various purposes, including, notably, determination of the tax base. That control has two aspects-verification and rectification-which are conceptually distinct functions that the rules of transfer pricing frequently elide. The control is invariably ineffective, to a greater or lesser extent, so transfer pricing practices always result in distortions and inject a note of voluntariness into supposedly compulsory tax systems. The core of the problem is the notion that a corporation (or trust or partnership, but the dominant presence here is the corporation) is separate both from its owners and from other corporations with the same ownership. This is, of course, nonsense. A corporation is a piece of paper. Pieces of paper controlled by identical interests cannot transact business with each other, not in the real world. Yet the respect that laws in all countries accord to the corporation as a separate person means that transfer pricing is a fact of economic life and that rules must be developed to deal with corporate transactions with related corporations. Market friction is lacking in these transactions, so the rules are the only way to achieve a modicum of restraint on manipulation. This is what the transfer pricing rules are all about."--Foreword

Language: eng

Work

Publication

Amsterdam, The Netherlands, IBFD, 2011

Extent: 1 online resource (xxxviii, 768 pages)

Note: Part of IBFD

Instance

Label: Transfer pricing and dispute resolution : aligning strategy and execution

Title: Transfer pricing and dispute resolution

Title remainder: aligning strategy and execution

Statement of responsibility: edited by Anuschka Bakker and Marc M. Levey

Contributor

Subject

Language: eng

Summary: ""Transfer pricing" relates to the pricing of transactions between related persons. The term is employed, however, not merely in reference to the existence of prices for those transactions but, more specifically, with regard to the control of those prices for various purposes, including, notably, determination of the tax base. That control has two aspects-verification and rectification-which are conceptually distinct functions that the rules of transfer pricing frequently elide. The control is invariably ineffective, to a greater or lesser extent, so transfer pricing practices always result in distortions and inject a note of voluntariness into supposedly compulsory tax systems. The core of the problem is the notion that a corporation (or trust or partnership, but the dominant presence here is the corporation) is separate both from its owners and from other corporations with the same ownership. This is, of course, nonsense. A corporation is a piece of paper. Pieces of paper controlled by identical interests cannot transact business with each other, not in the real world. Yet the respect that laws in all countries accord to the corporation as a separate person means that transfer pricing is a fact of economic life and that rules must be developed to deal with corporate transactions with related corporations. Market friction is lacking in these transactions, so the rules are the only way to achieve a modicum of restraint on manipulation. This is what the transfer pricing rules are all about."--Foreword

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