Transfer Pricing and Value Creation (eBook)

Schriftenreihe IStR, Band 116

Raffaele Petruzzi, Romero J. S. Tavares Esq. (Herausgeber)

eBook Download: EPUB

2019 | 1. Auflage
100 Seiten
Linde Verlag Wien Gesellschaft m.b.H.
978-3-7094-1038-7 (ISBN)

Infos

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.

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IXList of Authors

Jeanine Blumer

Jeanine Blumer graduated from the University of Applied Sciences in Winterthur, Switzerland, where she obtained her bachelor of law degree. She began to work as a tax consultant with a big four company in Zurich in 2008 before she obtained the Swiss tax expert certificate in 2012. Jeanine Blumer is specialized in the field of international tax consulting and arbitration. For the past four years, she has been working for Kendris Ltd. in Zurich which is an international fiduciary and family office company.

Dmitry Brodskiy

Dmitry Brodskiy received a bachelor, master, and PhD degrees in economics at the Moscow State University, Russia. He has been working as a financial analyst in Gazprom Neft Group since 2008. Currently, he is a head of controlling in Gazprom Neft Trading in Vienna, providing support in respect of direct and indirect taxation of cross-border transactions.

Monica Califano

Monica Califano graduated cum laude in Economics and Business Management at the University of Naples Federico II. She participated in various masters and courses of specialization in Italy and abroad including the International Business and Foreign Market at New York University, Master of specialization in Business Tax Law at IPSOA, Academy of American and International Law at the Southwestern Legal Foundation in Dallas, and LLM in International Tax Law at the Vienna University of Economics and Business Management – International Tax Center (WU). She has been working as a tax consultant since 2011. Currently, she is a senior tax advisor at Legance Avvocati Associati in Rome. She is a Professional Chartered Accountant and Auditor and a member of the committee “International Tax” of the Certified Public Accountants, Auditors and Advisors of Rome.

Werner Egger

Werner Egger received his degree in Business Administration at the Vienna University of Economics and Business Administration (WU). He has been working in advisory and accounting since 2002 and is a tax advisor and certified public accountant in Austria. He is now equity partner in the accounting firm CONFIDA Xin Vienna, advising local and international clients in relation to taxation and accounting as well as social security and other business-related questions.

Tereza Gebauer

Tereza Gebauer received her University Degree at the Faculty of Economics at Technical University in Ostrava and Faculty of Law at Masaryk University in Brno. She has been working in tax advisory since 2005, from 2013 she has been working for Deloitte Advisory in Prague.

Valeria Khmelevskaya

Valeria Khmelevskaya graduated from Moscow State Institute of International Relations (MGIMO University) with a bachelor degree in International Relations and Regional Studies and with an LLM in International and EU Law, both degrees with honors. Since 2001, she has been working as a lawyer in various law firms. Valeria has been admitted as a tax consultant since 2006. Currently, she is a partner and co-owner of the legal firm Brand & Partner and is a head of tax practice there. She is also a partner and co-owner of the accountancy firm KBK Accounting. Valeria holds the position of a deputy head of the Committee for Taxes and Reporting of the German-Russian Chamber of Commerce and participates in various initiatives directed at improving the Russian tax legislation, including VAT issues related to the services electronically supplied by foreign B2B providers, PE issues related to construction sites, etc. Valeria is also partnering with the Advantage Austria in Moscow and regularly provides support on taxation issues.

Pavlo Khodakovsky

Pavlo Khodakovsky is qualified Ukrainian attorney-at-law. He received a Master’s Degree in International Law at The Institute of International Relations at Kyiv National Taras Shevchenko University and a Master’s Degree in Foreign Policy at the Diplomatic Academy of Ukraine under the Ministry of Foreign Affairs of Ukraine. He has been working as a tax partner at Arzinger law firm since 2009. He is member of the Board of IFA Ukraine.

Viktoria Kraus

Viktoria Kraus received a degree in law at the University of Vienna. Currently, she is working as a tax advisor at KPMG Austria.

Pavlína Kropáčková

Pavlína Kropáčková graduated from the Faculty of International Business at the University of Economics in Prague. She has worked for several multinational consulting companies and has broad experience in IT project management and software architecture. She currently works in software product development and strategy. While delivering software services for clients in financial sector, she was XIfocusing on software solutions especially in area of international transactions which influenced her to pursue the LLM studies.

Monika Majerkova

Monika Majerkova received a master degree in sociology in the Palacky University in Olomouc, Czech Republic. She has been working in tax and economic advisory practices since 2009. Monika joined Deloitte’s M&A tax team in Prague in 2011 where she focuses on tax and accounting aspects of M&A transactions and restructuring, due diligence processes, international taxation, and corporate income taxation. She is a tax advisor registered in the Czech Chamber of Tax advisers.

Doris Schatzl

Doris Schatzl graduated in Economics and Business at the Vienna University of Economics and Business. She is a certified tax adviser according to Austrian professional law. Doris has over nine years of experience in advising international and local corporate clients. She joined PwC in 2016 and is a Tax Senior Manager at the Vienna office. She has experience in Austrian tax law, national and international tax structuring, and in M&A. She has been advising clients from multiple industries particularly in the area of Financial Services.

Stefan Schuster

Stefan Schuster received a master degree in economics at the University of Business and Economics Vienna (WU), a Master in Business Administration at the Alpen-Adria-University Klagenfurt, and a master degree in change management at the Danube-University Krems. Currently, he is head of taxes at A1 Telekom Austria and member of the board of A1now TV. In addition, he is a tax advisor and publishes regularly.

Yusuf Jamal Siddiqui

Yusuf J Siddiqui was born in Kolkata. After completing school in Darjeeling, he went on to complete his Bachelor of Law with honors from the University of Buckingham in 1998. He completed his training in Kolkata and New Delhi and qualified as an Advocate in India. In 2003, he completed his Master of Law in Intellectual Property from Southampton Institute, Nottingham Trent University. In 2010, he qualified as a Solicitor of the higher Courts of England & Wales and has been in the practice of intellectual property. Currently, he is pursuing his second Master of Law in International Tax from WU Vienna University for Business & Economics.

Martin Šimunek

Martin Šimunek received a degree in economics at the University of Economics in Prague and the Charles University in Prague. He has been working as a tax adXIIvisor since 2014. Presently, he is a partner with the company EDM Utilitas Tax, s.r.o.

Olga Solovyova

Olga Solovyova graduated in law and later graduated with honors in International Economy at the University in Ukraine. She has been working as a tax lawyer since 1998. Currently, she is a partner and head of International tax and finance law practice in Ukrainian and Estonian law offices. Also, Olga is national reporter from Estonia in the Tax Committee of the International Bar Association.

Paul Tiefling

Paul Tiefling received his degrees from the University of Innsbruck and the University of Klagenfurt. He has worked in various positions in financial institutions in the US as well as assistant professor at Temple University. Since 2010, he has been working as a tax advisor at Treuhand Union Klagenfurt for which he is a managing partner since 2013.

Matthias Werner

Matthias Werner graduated from the Vienna University of Economics and Business in 2004. He worked for more than ten years for a Big Four accounting firm in Vienna and Moscow. In 2010, he was sworn in as a tax advisor and certified public accountant in Austria. Currently, he is an associate partner at an accounting firm in Vienna.

Bernhard Winkelbauer

Bernhard Winkelbauer was born in Vienna in 1994. He received his bachelor‘s degree in economics at the Vienna University of Economics and Business in Austria and is currently finishing his master degree.

Shengjie Yan

Shengjie Yan was born in Shanghai and...

Produkt-Details

• Erscheint lt. Verlag: 2.9.2019
• Sprache: englisch
• Themenwelt: Recht / Steuern ► Steuern / Steuerrecht
• ISBN-10: 3-7094-1038-X / 370941038X
• ISBN-13: 978-3-7094-1038-7 / 9783709410387