: Oliver Treidler
: Transfer Pricing in One Lesson A Practical Guide to Applying the Arm's Length Principle in Intercompany Transactions
: Springer-Verlag
: 9783030250850
: 1
: CHF 47.50
:
: Management
: English
: 145
: Wasserzeichen/DRM
: PC/MAC/eReader/Tablet
: PDF
This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm's length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book's content is applicable to a global context.


Oliver Treidler is the CEO and founder of TP&C, a transfer pricing firm based in Berlin, Germany. He has extensive experience in supporting his clients in designing and optimizing transfer pricing structures as well as in conducting comparability analyses and compiling documentation. He holds a master's degree in international economics and European studies from the Corvinus University of Budapest, Hungary, and a Ph.D. in economics from the University of Würzburg, Germany. 

 

Foreword6
Contents9
About the Author10
Chapter 1: Introduction11
Chapter 2: The Lesson13
2.1 Developing a Broad Understanding of the Relevant Economic Conditions for Your Transactions16
2.2 Functional and Risk Analysis: Heart and Soul of Transfer Pricing21
Functions25
Research and Production25
Procurement25
Quality Assurance25
Logistics and Warehousing26
Sales and Marketing26
After-Sales26
Management and Administration26
Risks27
Research and Development Risk27
Product Liability and Quality Risk27
Market Risk28
Customer Credit Risk28
Functional and Risk Profile28
Chapter 3: Applying the Lesson to Basic Transactions35
3.1 The Comparable Uncontrolled Price (CUP) Method38
3.2 The Resale Price Method45
3.3 The Transactional Net Margin Method (TNMM)61
3.4 The Profit Split Method (PSM)74
Scenario (a): Prima Asia as ``Super Distributor´´83
Scenario (b): Merger with Rothwell Gornt88
3.5 The Cost Plus Method (C+)90
Chapter 4: Applying the Lesson to More Complex Transactions101
4.1 Management Services102
4.2 Financial Transactions115
Chapter 5: Documentation and Tax Audits127
Chapter 6: Closing Remarks: A Kind Word to Tax Auditors and Policymakers132
Annexes135
Annex A. Questionnaire: Transfer Pricing Basics135
Identification of Relevant Facts and Circumstances135
Annex B. Checklist for Benchmark Studies136
Guidance for Integrating Benchmark Studies into the Local File136
Commissioning a Local Benchmark Analysis138
Annex C. Application of a CUP License Fee: Case Study Variation for Prima Asia139
Bibliography144