Asia-Pacific Transfer Pricing

Informationen zum Autor Robert Feinschreiber (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. He has had numerous career highlights (e.g., youngest full-time law professor in the United States when appointed (Wayne State University), age 23; member of the litigation team for the first Asian transfer pricing case (Toyota)). In addition, he is a consultant with the United Nations (Brazil, China, and Russia). Feinschreiber is on the editorial board of Wolters Kluwer -- CCH, and Thomson -- RIA. He has written over 25 books and is the co-editor of Corporate Business Taxation Monthly (CCH). He speaks at numerous conferences in the United States and Asia. Margaret Kent (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. She focuses on law and international taxation. She has been involved in a number of international transactions (i.e., structured the termination of the $2 billion per year aid from Russia to Cuba; structured transfer pricing in Latin America: Argentina, Chile, Colombia, Costa Rica, and Venezuela). Kent is also the co-editor of Corporate Business Taxation Monthly (CCH). Klappentext An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businessesA comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders.Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad. Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region* Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the lawA complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad. Zusammenfassung An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businessesA comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders.Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permane...

Auteur

Robert Feinschreiber (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. He has had numerous career highlights (e.g., youngest full-time law professor in the United States when appointed (Wayne State University), age 23; member of the litigation team for the first Asian transfer pricing case (Toyota)). In addition, he is a consultant with the United Nations (Brazil, China, and Russia). Feinschreiber is on the editorial board of Wolters Kluwer -- CCH, and Thomson -- RIA. He has written over 25 books and is the co-editor of Corporate Business Taxation Monthly (CCH). He speaks at numerous conferences in the United States and Asia.

Margaret Kent (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. She focuses on law and international taxation. She has been involved in a number of international transactions (i.e., structured the termination of the $2 billion per year aid from Russia to Cuba; structured transfer pricing in Latin America: Argentina, Chile, Colombia, Costa Rica, and Venezuela). Kent is also the co-editor of Corporate Business Taxation Monthly (CCH).

Texte du rabat

An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businesses A comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders. Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad. Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region * Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the law A complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad.

Contenu

Preface xxi PART ONE: COUNTRY-BY-COUNTRY ANALYSIS 1 Chapter 1 Introduction 3 Chapter 2 Australia's Risk Assessment Transfer Pricing Approach 7 Chapter 3 Profit Attribution for a Dependent Chapter 4 Australia's Advance Pricing Arrangement Program 49 Chapter 5 China Implements Transfer Pricing Procedures 55 Chapter 6 Reporting Related Party Transactions in China 105 Chapter 7 Hong Kong Advance Ruling Cases: Taxability of Profits 121 Chapter 8 Hong Kong Transfer Pricing Guidelines 143 Chapter 9 Hong Kong Challenges Abusive Tax Schemes 175 Chapter 10 Winning Hong Kong's Landmark Transfer Pricing Case 185 Chapter 11 Transfer Pricing Litigation in India 205 Chapter 12 PE Issues Impact Indian Transfer Pricing 217 Chapter 13 Taxation of Travel Services in India 239 Chapter 14 Transfer Pricing in Indonesia 247 Chapter 15 Japan's Directive on Transfer Pricing Operations 251 Chapter 16 Selecting the Arm's Length Price in Japan 289 Chapter 17 Applying Japanese Intangible Transfer Pricing Methods 327 Chapter 18 Japanese Profi t Split Transfer Pricing Methods 345 Chapter 19 Japanese Guidelines Address Diverse T…