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Transfer Pricing is an issue that has material implications for tax risks faced by MNEs. Yet, pragmatic guidance on identifying and managing transfer pricing risk is lacking. Consequently, CFOs and other stakeholders tend to underestimate risks while overestimating the costs for mitigating such risks. The first objective of the Survival Guide is to shed light on typical transfer pricing risks and provide an intuitive "risk matrix" that is designed to help CFOs as well as tax advisors to develop a quantitative understanding of the relevant risks. The second objective is to outline targeted mitigation strategies. The mitigation strategies outlined in the Survival Guide are based on pragmatic considerations rather than complex analysis. The aim is to provide you with concise explanations and help you to differentiate between tasks that are considered a "must" for mitigation purposes and those that can be regarded as merely "nice to have" The immediate utilization of the Survival Guide is as a frame of reference for making informed decisions about the scope and target of your transfer pricing projects. The Survival Guide presents a framework for thinking about transfer pricing risk that will also benefit tax professionals as well as academics with an interest in understanding the nature of transfer pricing risks.
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.
Following the success of "Cryptolawgy: A Pioneering Resource on Crypto Laws and Regulations," Dah (Prince) Roland Amoussou releases a highly anticipated follow-up: "Cryptolawgy: A Survival Guide to Crypto Business Risks" (Crypto Contracts and Litigations Made Simple). This new volume responds to the growing demand for practical guidance to navigate the complexity of legal issues in the cryptocurrency space. Amoussou meticulously examines the intricate legal landscape surrounding cryptocurrency and blockchain technology in this comprehensive guide. The book offers invaluable insights for dealing with the multiplex web of regulations, contracts, and litigation in the rapidly evolving crypto industry. Key features of the book include: - Global Regulatory Overview: An exploration of diverse regulatory approaches across four continents, with detailed insights into key markets such as the United States, European Union, Japan, Thailand, Hong Kong, Mauritius, and Nigeria. - Legal Risk Assessment: A thorough analysis of the legal risks associated with cryptocurrency, including regulatory compliance, contractual disputes, anti-money laundering (AML), know-your-customer (KYC) requirements, and data protection laws. - Crypto Contracting Guide: A practical section for investors and entrepreneurs, covering contract fundamentals, unique aspects of crypto contracts, and implications of smart contracts. It also provides guidance on contracting processes, administration, and strategic management to minimize legal risks and ensure compliance. - Tax-related issues in crypto investment and operations - Litigation in Crypto Business: An in-depth look at common types of litigation in the crypto world, including civil lawsuits, regulatory enforcement actions, criminal prosecutions, tax disputes, and arbitration. Case studies of landmark cases such as SEC v. Ripple Labs offer valuable insights into legal processes and their potential industry impacts. - The Future of Dispute Resolution in Crypto and Blockchain Arbitration: A discussion on Smart Contracts and how arbitration works. - Digital Asset Definitions: A preliminary chapter emphasizing the importance of clear and precise definitions for digital assets, examining various jurisdictions to highlight commonalities and differences in regulatory approaches. - Guide Templates on various crypto-related contracts and agreements - A Real Cross-border case study involving crypto fraud in Thailand and the UK - How to Open and Operate a crypto account - A Checklist on surviving crypto-related legal issues. "Cryptolawgy" (Vol. 2) caters to a diverse audience, including retail investors, legal practitioners, entrepreneurs, business owners, students, and researchers. By providing guiding principles and in-depth analyses, this publication equips readers with the knowledge and tools to confidently navigate the legal challenges and opportunities in the dynamic and transformative crypto industry.
A nationally recognized expert on professional ethics uses pungent real-world examples to help people new to the work world recognize ethical situations that can lead to career-damaging mistakes—and prevent them. Gunsalus offers questions to ask yourself, sample scripts to use on others, and guidance in handling disputes fairly and diplomatically.
Reflecting the demands for entry-level accountants, the focus of this book is on fostering critical thinking skills, reducing emphasis on memorisation and encouraging more analysis and interpretation by requiring use of technology tools, spreadsheets and databases.
The Closer’s Survival Guide is perfect for sales people, negotiators, deal makers and mediators but also critically important for dreamers, investors, inventors, buyers, brokers, entrepreneurs, bankers, CEO’s, politicians and anyone who wants to close others on the way they think and get what they want in life. Show me any highly successful person, and I will show you someone who has big dreams and who knows how to close! The end game is the close.
Using handy checklists, worksheets, and examples, Davis helps readers face the challenges of deciding whether or not to use an agent, how to find one, estimating a price, and deciding which upgrades are worth making--and which ones are not--to add to their home's value.
Every organization, business, and manager is unique, and each demands an individually tailored management style. Supposedly universal management strategies must be tailored to suit the specific situations that each individual faces daily in the work environment. This book provides a theoretical and practical foundation for the adaptation and tailoring of a universal management style into a specific, effective style with the power to produce the desired results. It assists the manager, or would-be manager, in the development of a management style that meets the needs of any kind of business. Each chapter begins with a case study illustrating a typical problem followed by questions and answers about the presented challenges. The chapters also contain thought provoking one-sentence suggestions that can be immediately immplemented, enabling the reader to produce results and succeed in today's rapidly-evolving economic and technological environments. This work combines the best and latest in management theory with tested practical applications, making it a useful tool for managers not only in technically-orientated industries, but in any kind of company. Based upon the author's more than 25 years of experience in management consulting, writing, lecturing, and teaching, this work is designed to help readers handle the demanding responsibilities of technical management. It features important information in dealing with international firms, contracts, TQ, ISO 9000, and CAD management. It also provides essential details on personal liability and ethics in decision making, motivating employees, leadership, and creating teams. The Technical Manager's Handbook serves as a valuable, cross-method reference for engineers, scientists, researchers, and students who are or soon will be involved in technical management operations. Managers in quality assurance, manufacturing, administration, and computer manufacturing will also benefit from this volume's accessible and applicable exploration of pertinent issues.
Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.
"Between phones, networks, equipment, and vendors, being a telecom manager can be a difficult task. Using four companies' actual experiences as case studies, The Telecom Manager's Survival Guide presents an easily understandable method for lining up the best possible services, putting the right tools in place, and saving the business money. The book takes a practical approach, providing a proactive system for: * Project management for the implementation of new services * Trouble resolution for equipment * Billing audit and reviews * Strategic planning for the future The Telecom Manager's Survival Guide is an important resource for anyone taking charge of their organization's telecommunications initiatives."