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Issues of transfer pricing have come to the fore in both international tax and customs regimes. In particular, the problem of how to apply the two systems of valuation to the same transaction is of widespread concern. This well-known book, now in a fully updated second edition, is a problem-solving guide for professionals charged with valuating transactions in their client’s or company’s best interests. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, it offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized. Among other essential elements, the author discusses the following in depth: – the OECD Transfer Pricing Guidelines; – the GATT/WTO Customs Valuation Code (GVC) and other valuation rules in key jurisdictions and regional agreements; – the OECD and UN model tax conventions; – the arm’s length principle; – methods, both traditional and new, of determining whether the parties’ relationship in uenced the price; and – additions to and deductions from the customs value. This second edition discusses new developments in the eld, including a chapter on Commentary 23.1 and Case Study 14.1 of the Technical Committee on Customs Valuation of the World Customs Organization (WCO) – the rst international instruments linking transfer pricing and customs valuation. The book concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing year-end adjustments to transaction value would be consistent with Article 1 of the GVC. The book will continue to provide practitioners, customs administrations, and academics with a highly practical analysis of the intersection of transfer pricing and customs valuation. It will be welcomed by customs administrations charged with examining the acceptability of a transaction value xed between related parties and by multinational companies as a truly actionable tool they can use to optimize decision-making as it relates to transfer pricing and customs valuation in a “real world” setting.
Although valuation is fundamental to both tax and customs liability in international transactions, values calculated by the two regimes can differ, often markedly, in situations where no clear rules of transfer pricing apply. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, Customs Valuation and Transfer Pricing offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized.Among the essential elements of this important thesis, the author discusses the following in depth: the OECD Transfer Pricing Guidelines; the GATT/WTO Valuation Code (GVC); the arm's length principle; methods, both traditional and new, of determining whether the parties' relationship influenced the price; and additions to and deductions from the customs value. The study concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing compensatory adjustments to transaction value would be consistent with Article 1 of the GVC.
Intended to provide the basic foundation for modern archival practice and theory.
This now famous White Paper provides rules for our digital highway.Ó Examines each of the major areas of intellectual property law, focusing primarily on copyright law & its application & effectiveness, especially subject matter & scope of protection, copyright ownership, term of protection, exclusive rights, limitations on exclusive rights, copyright infringement. Holds Internet service providers legally accountable for copyright & other infringements by their users. Judges are beginning to use this document to form case law.
Tax Guide 2015 provides comprehensive coverage of all areas of taxation applicable to Ireland. Written in non-technical language by an expert team of tax practitioners, it covers:Income Tax; Capital Gains Tax; Value Added Tax; Employers' PAYE/PRSI; Corporation Tax; Capital Acquisitions Tax; Stamp Duties; Vehicle Registration Tax and Customs and Excise.As well as taking on board the provisions of the latest Finance Act it features detailed worked examples and extensive references to recent case law. It also contains a set of tables giving speedy access to allowances, tax rates, compliance deadlines and other invaluable information.Tax Guide 2015 is an ideal reference book that serves as a self-contained textbook and as a pointer to more detailed Bloomsbury Professional publications, such as Irish Income Tax, The Taxation of Companies, Irish Stamp Duty Law and Capital Acquisitions Tax.Previous edition ISBN: 9781780434612
The population and housing census is part of an integrated national statistical system, which may include other censuses (for example, agriculture), surveys, registers and administrative files. It provides, at regular intervals, the benchmark for population count at national and local levels. For small geographical areas or sub-populations, it may represent the only source of information for certain social, demographic and economic characteristics. For many countries the census also provides a solid framework to develop sampling frames. This publication represents one of the pillars for data collection on the number and characteristics of the population of a country.