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
Resource Information
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.This item is available to borrow from 1 library branch.
Resource Information
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.
This item is available to borrow from 1 library branch.
- 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
- Extent
- 1 online resource (xxxviii, 768 pages)
- Note
- Part of IBFD
- 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
- 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
- Member of
- JWeRbkJSPHY
- Cataloging source
- AU@
- http://bibfra.me/vocab/lite/collectionName
- IBFD online books
- Illustrations
- illustrations
- Index
- no index present
- Literary form
- non fiction
- Nature of contents
- dictionaries
- http://library.link/vocab/relatedWorkOrContributorName
-
- Bakker, Anuschka
- Levey, Marc M
- International Bureau of Fiscal Documentation
- http://library.link/vocab/subjectName
-
- Transfer pricing
- Dispute resolution (Law)
- Label
- Transfer pricing and dispute resolution : aligning strategy and execution, edited by Anuschka Bakker and Marc M. Levey
- Note
- Part of IBFD
- Carrier category
- online resource
- Carrier category code
- cr
- Carrier MARC source
- rdacarrier
- Color
- multicolored
- Content category
- text
- Content type code
- txt
- Content type MARC source
- rdacontent
- Dimensions
- unknown
- Extent
- 1 online resource (xxxviii, 768 pages)
- Form of item
- online
- Governing access note
- Restricted to users at subscribing institutions
- Media category
- computer
- Media MARC source
- rdamedia
- Media type code
- c
- Sound
- unknown sound
- Specific material designation
- remote
- System control number
- (OCoLC)792754185
- System details
- Mode of access: World Wide Web
- Label
- Transfer pricing and dispute resolution : aligning strategy and execution, edited by Anuschka Bakker and Marc M. Levey
- Note
- Part of IBFD
- Carrier category
- online resource
- Carrier category code
- cr
- Carrier MARC source
- rdacarrier
- Color
- multicolored
- Content category
- text
- Content type code
- txt
- Content type MARC source
- rdacontent
- Dimensions
- unknown
- Extent
- 1 online resource (xxxviii, 768 pages)
- Form of item
- online
- Governing access note
- Restricted to users at subscribing institutions
- Media category
- computer
- Media MARC source
- rdamedia
- Media type code
- c
- Sound
- unknown sound
- Specific material designation
- remote
- System control number
- (OCoLC)792754185
- System details
- Mode of access: World Wide Web
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.law.upenn.edu/portal/Transfer-pricing-and-dispute-resolution-/QU23v9cwOcs/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.law.upenn.edu/portal/Transfer-pricing-and-dispute-resolution-/QU23v9cwOcs/">Transfer pricing and dispute resolution : aligning strategy and execution, edited by Anuschka Bakker and Marc M. Levey</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.law.upenn.edu/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.law.upenn.edu/">Biddle Law Library</a></span></span></span></span></div>
