TAXATION AND VALUE CREATION.

TAXATION AND VALUE CREATION.

Author:

Publisher:

Published: 2021

Total Pages:

ISBN-13: 9789087226879

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Book Synopsis TAXATION AND VALUE CREATION. by :

Download or read book TAXATION AND VALUE CREATION. written by and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:


Transfer Pricing and Value Creation

Transfer Pricing and Value Creation

Author: Raffaele Petruzzi

Publisher: Linde Verlag GmbH

Published: 2019-09-02

Total Pages: 472

ISBN-13: 370941038X

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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.


Book Synopsis Transfer Pricing and Value Creation by : Raffaele Petruzzi

Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi and published by Linde Verlag GmbH. This book was released on 2019-09-02 with total page 472 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.


Taxation and Value Creation

Taxation and Value Creation

Author: Werner C. Haslehner

Publisher:

Published: 2021

Total Pages:

ISBN-13: 9789087226893

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This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework


Book Synopsis Taxation and Value Creation by : Werner C. Haslehner

Download or read book Taxation and Value Creation written by Werner C. Haslehner and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework


Transfer Pricing and Value Creation

Transfer Pricing and Value Creation

Author: Raffaele Petruzzi

Publisher:

Published: 2019

Total Pages: 556

ISBN-13: 9783707341232

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Book Synopsis Transfer Pricing and Value Creation by : Raffaele Petruzzi

Download or read book Transfer Pricing and Value Creation written by Raffaele Petruzzi and published by . This book was released on 2019 with total page 556 pages. Available in PDF, EPUB and Kindle. Book excerpt:


Tax and the Digital Economy

Tax and the Digital Economy

Author: Werner Haslehner

Publisher: Kluwer Law International B.V.

Published: 2019-05-01

Total Pages: 370

ISBN-13: 9403503351

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The increasingly digitalized global economy is undermining the usefulness of many traditional tax concepts. In addition to issues of double taxation and double non-taxation, important questions arise concerning the allocation of taxing rights in respect of income from cross-border digital transactions. This is the first book to analyse what changes are possible, necessary and feasible in order to forestall the unravelling of the existing international tax framework. Focusing in turn on the legal framework, specific proposals for adapting tax concepts for the digital economy, types of transactions and administrative issues such as those around data protection and digital currencies, the expert contributors discuss such challenges to taxation as the following: the pervasiveness of intangible assets; new value creation models; the ascendance of the sharing economy and digital services; virtual currencies; the importance of user participation for digital platforms; cloud computing; the impact of Big Data on tax enforcement; virtual business presence; and the influence of robotization. Throughout, the authors describe and analyse proposals made by the Organisation for Economic Co-operation and Development (OECD), the European Union (EU) and individual countries and their likely impact going forward. They also attend to the limits imposed on reform possibilities by public international law, EU law and constitutional law. It is generally acknowledged that there is a need to monitor how the digital transformation may be impacting value creation. This book is a key milestone toward developing a durable, long-term solution to the tax challenges posed by the digitalization of the economy. With its thorough scrutiny of proposals for digital services tax and virtual permanent establishments, insightful analysis of digital services and detailed description of the impact of big data on tax administration and taxpayer protection, it will quickly prove indispensable for tax practitioners and the international tax community more generally.


Book Synopsis Tax and the Digital Economy by : Werner Haslehner

Download or read book Tax and the Digital Economy written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2019-05-01 with total page 370 pages. Available in PDF, EPUB and Kindle. Book excerpt: The increasingly digitalized global economy is undermining the usefulness of many traditional tax concepts. In addition to issues of double taxation and double non-taxation, important questions arise concerning the allocation of taxing rights in respect of income from cross-border digital transactions. This is the first book to analyse what changes are possible, necessary and feasible in order to forestall the unravelling of the existing international tax framework. Focusing in turn on the legal framework, specific proposals for adapting tax concepts for the digital economy, types of transactions and administrative issues such as those around data protection and digital currencies, the expert contributors discuss such challenges to taxation as the following: the pervasiveness of intangible assets; new value creation models; the ascendance of the sharing economy and digital services; virtual currencies; the importance of user participation for digital platforms; cloud computing; the impact of Big Data on tax enforcement; virtual business presence; and the influence of robotization. Throughout, the authors describe and analyse proposals made by the Organisation for Economic Co-operation and Development (OECD), the European Union (EU) and individual countries and their likely impact going forward. They also attend to the limits imposed on reform possibilities by public international law, EU law and constitutional law. It is generally acknowledged that there is a need to monitor how the digital transformation may be impacting value creation. This book is a key milestone toward developing a durable, long-term solution to the tax challenges posed by the digitalization of the economy. With its thorough scrutiny of proposals for digital services tax and virtual permanent establishments, insightful analysis of digital services and detailed description of the impact of big data on tax administration and taxpayer protection, it will quickly prove indispensable for tax practitioners and the international tax community more generally.


OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

Author: OECD

Publisher: Org. for Economic Cooperation & Development

Published: 2015-10-19

Total Pages: 186

ISBN-13: 9789264241237

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The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.


Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-19 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.


Distortions Created by Taxes which are Options on Value Creation

Distortions Created by Taxes which are Options on Value Creation

Author: Ray Ball

Publisher:

Published: 1983

Total Pages: 29

ISBN-13: 9780858234253

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Book Synopsis Distortions Created by Taxes which are Options on Value Creation by : Ray Ball

Download or read book Distortions Created by Taxes which are Options on Value Creation written by Ray Ball and published by . This book was released on 1983 with total page 29 pages. Available in PDF, EPUB and Kindle. Book excerpt:


OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

Author: OECD

Publisher: OECD Publishing

Published: 2015-10-05

Total Pages: 190

ISBN-13: 9264241248

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Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Actions 8-10.


Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 190 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Actions 8-10.


Valuation Methods and Shareholder Value Creation

Valuation Methods and Shareholder Value Creation

Author: Pablo Fernandez

Publisher: Academic Press

Published: 2002-08-30

Total Pages: 662

ISBN-13: 0122538412

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This text provides a catalogue of valuation tools, together with guidance on analyzing and valuing a business. The author breaks down the topic to provide advice for any business, no matter how complex. He presents eight different methods of firm valuation and discusses the benefits and limitations of each method, supporting this information with examples from international markets.


Book Synopsis Valuation Methods and Shareholder Value Creation by : Pablo Fernandez

Download or read book Valuation Methods and Shareholder Value Creation written by Pablo Fernandez and published by Academic Press. This book was released on 2002-08-30 with total page 662 pages. Available in PDF, EPUB and Kindle. Book excerpt: This text provides a catalogue of valuation tools, together with guidance on analyzing and valuing a business. The author breaks down the topic to provide advice for any business, no matter how complex. He presents eight different methods of firm valuation and discusses the benefits and limitations of each method, supporting this information with examples from international markets.


Organizing for Sustainability

Organizing for Sustainability

Author: Jan Jonker

Publisher: Springer Nature

Published: 2021

Total Pages: 259

ISBN-13: 3030781577

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This upper-level Open Access textbook aims to educate students and professionals on how to develop business models that have a positive impact on people, society, and the social and ecological environment. It explores a different view of how to organize value creation, from a focus on an almost exclusively monetary value creation to one that creates positive impact through multiple values. The book offers students and entrepreneurs a structured approach based through the Business Model Template (BMT). It consists of three stages and ten building blocks to facilitate the development of a business model. Users, be they students or practitioners, need to choose from one of the three offered business model archetypes, namely the platform, community, or circular business models. Each archetype offers a dedicated logic for vale creation. The book can be used to develop a business model from scratch (turning an idea into a working prototype) or to transform an existing business model into one of the three archetypes. Throughout the book extra sources, links to relevant online video clips, assignments and literature are offered to facilitate the development process. This book will be of interest to students studying the development of business models, sustainable management, innovation, and value creation. It will also be of interest executives, and professionals such as consultants or social entrepreneurs seeking further education.-- Provided by publisher.


Book Synopsis Organizing for Sustainability by : Jan Jonker

Download or read book Organizing for Sustainability written by Jan Jonker and published by Springer Nature. This book was released on 2021 with total page 259 pages. Available in PDF, EPUB and Kindle. Book excerpt: This upper-level Open Access textbook aims to educate students and professionals on how to develop business models that have a positive impact on people, society, and the social and ecological environment. It explores a different view of how to organize value creation, from a focus on an almost exclusively monetary value creation to one that creates positive impact through multiple values. The book offers students and entrepreneurs a structured approach based through the Business Model Template (BMT). It consists of three stages and ten building blocks to facilitate the development of a business model. Users, be they students or practitioners, need to choose from one of the three offered business model archetypes, namely the platform, community, or circular business models. Each archetype offers a dedicated logic for vale creation. The book can be used to develop a business model from scratch (turning an idea into a working prototype) or to transform an existing business model into one of the three archetypes. Throughout the book extra sources, links to relevant online video clips, assignments and literature are offered to facilitate the development process. This book will be of interest to students studying the development of business models, sustainable management, innovation, and value creation. It will also be of interest executives, and professionals such as consultants or social entrepreneurs seeking further education.-- Provided by publisher.