Transfer Pricing and Value Creation
Linde Verlag Ges.m.b.H.
978-3-7073-4123-2 (ISBN)
Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Value Creation and its effects on Transfer Pricing and tax law
Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of 'Value Creation' reframes the interpretation and application of the Arm's Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways.
Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.
Raffaele Petruzzi is the Managing Director of the WU Transfer 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 tax and transfer pricing at Baker McKenzie, where is part of the EMEA Transfer Pricing Group and is the Head of the Austria Transfer Pricing Group. Raffaele has gained extensive experience in dealing with topics related to international tax and transfer pricing for many years, both from a professional and an academic side. He is a frequent speaker in international conferences and lecturer of numerous courses all over the world, as well as author of many publications. Finally, amongst others, he is a member of the United Nations Subcommittee on Transfer Pricing, of the International Fiscal Association (IFA), and of Transfer Pricing Economists for Development (TPED). Raffaele holds a Ph.D. in International Business Taxation at WU, an LL.M. in International Tax Law at WU, and an M.Sc. in Business Administration and Law at Bocconi University.
Romero J. S. Tavares Esq., A research associate and lecturer at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business). He is a Partner in the PwC Global Core Team (Global Tax Policy & Administration) specializing in Global Integrated Structuring and Value Chain Transformation and is the Leader of International Tax Services and Transfer Pricing at PwC in Brazil. He is also an adjunct Professor of International Tax Policy and Tax Law in São Paulo.
| Erscheinungsdatum | 10.09.2019 |
|---|---|
| Reihe/Serie | Schriftenreihe zum Internationalen Steuerrecht ; 116 |
| Sprache | englisch |
| Maße | 155 x 225 mm |
| Gewicht | 1000 g |
| Einbandart | kartoniert |
| Themenwelt | Recht / Steuern ► Steuern / Steuerrecht ► Internationales Steuerrecht |
| Schlagworte | DBA • Doppelbesteuerung • Verrechnungspreise |
| ISBN-10 | 3-7073-4123-2 / 3707341232 |
| ISBN-13 | 978-3-7073-4123-2 / 9783707341232 |
| Zustand | Neuware |
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