000			02315cam a2200301 i 4500
001			19702084
003			KE-NaKCAU
005			20250808153417.0
008			170612s2017 enk b 001 0 eng d
010			_a 2017945341
020			_a9780198802914
035			_a(OCoLC)ocn991787382
040			_aYDX _beng _erda _cKE-NaKCAU _dLSD _dCDX _dOCLCF _dGUL _dDLC
042			_alccopycat
050	0	0	_aK4544 _b.C648 2017
100	1		_aCollier, Richard S., _eauthor.
245	1	0	_aTransfer pricing and the arm's length principle after BEPS / _cRichard S Collier, Joseph L Andrus.
260			_aOxford : _bOxford University Press, _c2017.
300			_axviii, 306 pages : _billustrations ; _c26 cm.
504			_aIncludes bibliographical references and index.
520	8		_aThis is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle starting with an explanation of how the rules were created and and how they evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS project, and describes the principal problems that had arisen with those rules. The issues highlighted include problems relating to the complexity of the rules, the use and availability of comparables, and, in particular, problems permitting avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS rules and inherent problems, the book goes on to examine the extent to which the work undertaken by the BEPs project provides a solid foundation for future transfer pricing determinations and the problems that remain after BEPS.0It identifies those issues on which the BEPS output has been positive, and also those issues which BEPS has not successfully addressed and which remain problematic.
650		0	_aInternational business enterprises _xLaw and legislation. _913085
650		0	_aTransfer pricing _xLaw and legislation.
650		0	_aTransfer pricing.
700	1		_aAndrus, Joseph L., _eauthor.
906			_a7 _bcbc _ccopycat _d2 _eepcn _f20 _gy-gencatlg
942			_2lcc _cBK
999			_c18754 _d18754