Transfer Pricing Developments Around the World 2020 - Hardcover

Lang; Michael; Petruzzi; Raffaele

Hardcover

ISBN 10: 9403523921 ISBN 13: 9789403523927

Publisher: Wolters Kluwer, 2020

Synopsis

Intensive work on transfer pricing, one of the most relevant and challenging topics in the international tax environment, continues to increase worldwide at every level of government and international policy with far-reaching impact on countries' legislations, administrative guidelines and jurisprudence. This book presents an in-depth, issue-by-issue analysis of the current state of developments along with suggestions for future solutions to the problems raised.

Emerging from the research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), this book offers eight topic-based chapters prepared by international experts on transfer pricing. Greatly helping to define recent transfer pricing issues around the world, this book encompasses the following topics:

• Global Transfer Pricing Developments;
• Transfer Pricing Developments in the European Union;
• Transfer Pricing Developments in the United States;
• Transfer Pricing Developments in Developing Countries and Emerging Economies;
• Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Nexus Rules);
• Recent Developments on the Tax Challenges Arising from the Digitalization of the Economy (New Profit Allocation Rules);
• Recent Developments on Transfer Pricing and Intra-Group Financing; and
• Recent Developments on the Use of New Technologies for Transfer Pricing Analyses.

The intense work of international organizations, such as the Organisation for Economic Co-operation and Development, United Nations and other international organizations, as well as the intense work of the European Union is thoroughly analyzed in this book.

The detailed analysis will be of immeasurable value to the various players including international organizations, the business community and advisory firms, corporate CEOs and CFOs, and government officials as well as to tax lawyers, in-house counsel and academics in facilitating efficient dialogue and a coordinated approach to transfer pricing in the future.

About this title

About the Author

Prof. Dr. DDr. h.c. Michael Lang is Head of the Institute for Austrian and International Tax Law of WU (Vienna University of Economics and Business, Austria) and academic director of both the LL.M. Program in International Tax Law and the Doctoral Program in International Business Taxation (DIBT) of this university. He is president of the Austrian Branch of the International Fiscal Association (IFA) and has been a visiting professor at Georgetown University, Washington, DC; New York University, New York; Sorbonne, France; Bocconi, Italy; Peking University (PKU), China; University of New South Wales (Sydney), and at other universities. Dr. Raffaele Petruzzi is the Managing Director of theWUTransfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business) and an international tax advisor specializing in international corporate taxation and transfer pricing at L&P Global (Vienna, Austria) and at Ludovici Piccone & Partners (Milan, Italy). Since 2007, Raffaele has gained extensive experience in dealing with topics related to international corporate taxation and transfer pricing, both from a professional and an academic perspective. From the professional perspective, he has gained relevant experience in advising clients on specific topics (e.g., international tax issues and transfer pricing issues related to services, permanent establishments, financing, business restructuring, intangibles, and indirect taxes), international tax and transfer pricing risk management and compliance, drafting and reviewing intra-group agreements, optimizing international tax structures, as well as implementing mechanisms of dispute avoidance (e.g., rulings and APAs) and dispute resolution (e.g., MAPs and arbitrations). From the academic perspective, he is a frequent speaker in international conferences and lecturer of numerous courses (in Europe, Asia, and Latin America), as well as author of many publications on international tax and transfer pricing topics. Moreover, he regularly cooperates with professionals in advisory, the business community, governments and international organizations (e.g., OECD, United Nations, World Bank Group, European Commission). Inter alia, he has gained experience in providing assistance on tax policy issues, capacity building for tax administrations, and advising governments on projects related to fight against tax evasion. Finally, among others, he is a member of the United Nations Subcommittee on Article 9 (Associated enterprises: Transfer Pricing), of the International Fiscal Association (IFA), and of Transfer Pricing Economists for Development (TPED). Raffaele holds a Master of Science in Business Administration and Law (major: Corporate Taxation) at Bocconi University (Italy), a Master of Laws (LL.M.) in International Tax Law at WU, and a Ph.D. in International Business Taxation at WU.

Edition details

• Publisher: Wolters Kluwer
• Publication date: 2020
• Language: English
• ISBN 10: 9403523921
• ISBN 13: 9789403523927
• Binding: Hardcover
• Number of pages: 256