Transfer Pricing Handbook / Wiley Corporate F&A (PDF)

PART ONE: BASIC TRANSFER PRICING STANDARDS Look at the basic OECD transfer pricing standards, beginning with the arm's length principle and the limits to this arm's length range concept. Examine the OECD's safe harbors simplification approaches and to its safe harbor modifications. Analyze the global formulary apportionment alternative. Chapter 1: Introduction Chapter 2: Arm's Length Principle Chapter 3: Arm's Length Range Chapter 4: Safe Harbor Simplification Chapter 5: Modifying Safe Harbor Simplification Chapter 6: Global Formulary Apportionment PART TWO: TRANSFER PRICING METHODOLOGIES Look at the OECD's transfer pricing methodologies, recognizing the importance of the transactional profit split alternative, the application of the residual profit split, and limitations on the transactional net margin method. Examine profit indicators and other transfer pricing ramifications. Chapter 7: Transactional Profit Split Measures Chapter 8: Profits Split Illustrations Chapter 9: Residual Profit Split Examples Chapter 10: Transactional Net Margin Method Chapter 11: Selecting Profit Indicators Chapter 12: Selecting Transfer Pricing Methods PART THREE: COMPARABILITY ANALYSIS Take a comprehensive look at comparability analysis, examining how the specifics of the comparability process and comparability analysis techniques, as well as the timing issues that arise in assessing comparability. Chapter 13: How Comparability Analysis Works Chapter 14: Comparability Techniques Chapter 15: Timing and Comparability PART FOUR: ADMINISTRATIVE APPROACHES Examine the OECD's administrative approaches. Look to audits and advance pricing agreement techniques, and examine the monitoring process itself. Chapter 16: Transfer Pricing Audits Chapter 17: Monitoring the Guidelines PART FIVE: ADVANCED OECD ANALYSIS Gain insight into advanced OECD analysis. Examine the documentation requirements, intangible properties, and services arrangements. Analyze cost contribution arrangements and business

Robert Feinschreiber (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. He has had numerous career highlights (e.g., member of the litigation team for the first Asian transfer pricing case (Toyota)). In addition, he is a consultant with the United Nations (Brazil, China, and Russia). Feinschreiber is on the editorial board of Wolters Kluwer - CCH, and Thomson - RIA. He has written over 25 books and is the co-editor of Corporate Business Taxation Monthly (CCH). He speaks at numerous conferences in the United States and Asia.

Margaret Kent (Key Biscayne, FL) is an attorney with Feinschreiber and Associates. She focuses on law and international taxation. She has been involved in a number of international transactions (i.e., structured the termination of the $2 billion per year aid from Russia to Cuba; structured transfer pricing in Latin America: Argentina, Chile, Colombia, Costa Rica, and Venezuela). Kent is also the co-editor of Corporate Business Taxation Monthly (CCH).

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