U.S. Tax Court Rules that Profits Should Reflect the Location of Valuable Intangibles Based on an Evidence-based Analysis : Comments on the Landmark Coca-Cola Case where the IRS Prevails Over Intercompany Royalties

U.S. Tax Court Rules that Profits Should Reflect the Location of Valuable Intangibles Based on an Evidence-based Analysis : Comments on the Landmark Coca-Cola Case where the IRS Prevails Over Intercompany Royalties
Author: M.S. Screpante
Publisher:
Total Pages:
Release: 2021
Genre:
ISBN:

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The Coca-Cola case constitutes another landmark case in the transfer pricing field that applies subliminally the notions of accurate delineation, commercial rationality and value creation embedded in the 2017 OECD Transfer Pricing Guidelines. Even though the U.S. Tax Court did not refer expressly to these notions, it put forward its reasoning on an evidence-based analysis of what happened (accurate delineation), why it happened (commercial rationality) and where it is appropriate to conclude where compensable value was created to align with where profits should be allocated. The trilogy of these notions (accurate delineation, commercial rationality and value creation) has gained great momentum since the launch of the BEPS project as if it were something new. Case law not only from the U.S. but also from other jurisdictions, e.g., Canada and Australia, shows that profit allocation in the transfer pricing context has always been a matter of evidence-based analysis based on what, why and where an income generating activity really happened. In fact, such an analysis is the only point of reference for these loose terms that have no legal significance in themselves apart from splitting profits based on economic facts which is considered to be genuine if the arrangements by which profits are generated are accurately delineated and commercially rational, and, therefore, value is created. The author explores how profits associated with supposed marketing intangibles are so readily allocated to the supply point foreign affiliates in the Coca-Cola organisation simply by entering into contracts when, actually, marketing activities were essentially performed by service affiliates.

Multinational Enterprises and the Global Economy

Multinational Enterprises and the Global Economy
Author: John H. Dunning
Publisher: Edward Elgar Publishing
Total Pages: 947
Release: 2008-01-01
Genre: Business & Economics
ISBN: 1848441320

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For many years to come this volume. . .is surely going to be the ultimate reference work on international business. . . thanks to Dunning and Lundan, have at their disposal, a wealth of relevant data, as well as theoretical and empirical analyses, which will enable them to assess the capabilities, contributions and challenges posed by the multinational enterprises to the global economy. Seev Hirsch, International Business Review Multinational Enterprises and the Global Economy has become a classic in international business. . . Yet , the book s second edition is even better than the first, in part because of Professor Dunning s wise decision to choose Dr Lundan as his co-author and to draw upon her deep knowledge of various strands of research on business government relations and the societal effects of firm behaviour. . . In addition to being a remarkably useful reference book, Multinational Enterprises and the Global Economy is the first book any IB doctoral student should read to understand the significance and richness of IB scholarship as it has developed over the past 50 years. Alain Verbeke, Journal of International Business Studies The second edition of Multinational Enterprises and the Global Economy provides unparalleled coverage not only of the literature relevant to IB research but also of the evolution of IB in the world economy. Dunning and Lundan offer powerful insights into the societal effects of MNEs and the role of business government relations in the IB context. Journal of International Business Studies This wonderful book offers the definitive synthesis of the modern literature on the economic aspects of international business. It is encyclopedic yet full of incisive insights. It is a creative masterpiece which unbundles the DNA of the multinational enterprise and shows how it is the cornerstone of the field of international business. Alan M. Rugman, University of Reading, UK The rise of the multinational enterprise, and the consequent globalisation of the world economy, was arguably the single most important phenomenon of the second half of the twentieth century. This magisterial book, written by two leading authorities, examines this phenomenon in depth. It explains how foreign investment by multinationals diffused advanced technologies and novel management methods, driving productivity growth in Europe, Asia and North America; however, economic inequalities were reinforced as rich countries attracted more foreign investment than poor ones. This new edition of a classic work is not only an authoritative guide to contemporary multinational business, but a major historical resource for the future. Mark Casson, University of Reading, UK This thoroughly updated and revised edition of a widely acclaimed, classic text will be required reading for academics, policymakers and advanced students of international business worldwide. Employing a distinctive and unified framework, this book draws together research across a range of academic fields to offer a synthesis of the determinants of MNE activity, and its effects on the economic and social well-being of developed and developing countries. Unique to the new edition is its focus on the institutional underpinnings of the resources and capabilities of MNEs, and the role of MNE activity in transmitting and facilitating institutional change. Since the initial publication of this book more than a decade ago, the economic, managerial and social implications of globalisation and technological advancement have become even more varied and prominent. Accompanying these developments, there has been a rise in scholarly interest in interdisciplinary research addressing the important challenges of an ever-changing physical and human environment. Drawing on articles and books from international business and economics, as well as economic geography, political economy and strategic management, a systematic overview of the developments in scholarly thinking is prese

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017
Author: OECD
Publisher: OECD Publishing
Total Pages: 612
Release: 2017-07-10
Genre:
ISBN: 9264265120

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This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

Auditing & Assurance Services

Auditing & Assurance Services
Author:
Publisher:
Total Pages:
Release: 2015
Genre: Auditing
ISBN: 9781259385650

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Art of M and A Due Diligence

Art of M and A Due Diligence
Author: Alexandra Reed Lajoux
Publisher: McGraw Hill Professional
Total Pages: 504
Release: 2000
Genre: Law
ISBN: 9780071378796

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The Art of M&A Due diligence is today's most useful guidebook for uncovering problems and inconsistencies while they are still manageable.

Havens in a Storm

Havens in a Storm
Author: J. C. Sharman
Publisher: Cornell University Press
Total Pages: 305
Release: 2018-10-22
Genre: Political Science
ISBN: 1501732900

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Small states have learned in recent decades that capital accumulates where taxes are low; as a result, tax havens have increasingly competed for the attention of international investors with tax and regulatory concessions. Economically powerful countries including France, Britain, Japan, and the United States, however, wished to stanch the offshore flow of domestic taxable capital. Since 1998 the Organisation for Economic Co-operation and Development (OECD) has attempted to impose common tax regulations on more than three dozen small states. In a fascinating book based on fieldwork and interviews in twenty-two countries in the Caribbean, North America, Europe, and islands in the Pacific and Indian Oceans, J. C. Sharman shows how the struggle was decided in favor of the tax havens, which eventually avoided common regulation. No other book on tax havens is based on such extensive fieldwork, and no other author has had access to so many of the key decision makers who played roles in the conflict between onshore and offshore Sharman suggests that microstates succeeded in their struggle with great powers because of their astute deployment of reputation and effective rhetorical self-positioning. In effect, they persuaded a transnational audience that the OECD was being untrue to its own values by engaging in a hypocritical, bullying exercise inimical to free competition.

Barron's Finance and Investment Handbook

Barron's Finance and Investment Handbook
Author: John Downes
Publisher: Barron's Educational Series
Total Pages: 1016
Release: 1986
Genre: Business & Economics
ISBN:

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Includes "listings with addresses of NYSE, AMEX and NASDAQ (NMS) stocks, directories of mutual funds, investment newsletters and financial institutions ... reflects latest federal tax laws."

GLOBAL LEGAL INSIGHTS

GLOBAL LEGAL INSIGHTS
Author:
Publisher:
Total Pages: 0
Release: 2021
Genre:
ISBN: 9781839181320

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International Transfer Pricing

International Transfer Pricing
Author: Business International Corporation
Publisher:
Total Pages: 212
Release: 1991
Genre: Foreign exchange
ISBN:

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A comprehensive guide to corporate practices in internal control and tax compliance. Included are case studies of how firms in a variety of industries approach transfer pricing.

A Sugary Drinks Tax

A Sugary Drinks Tax
Author: Stephen Duckett
Publisher:
Total Pages:
Release: 2016-11-22
Genre:
ISBN: 9781925015959

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