Transfer Pricing and Developing Economies : A Handbook for Policy Makers and Practitioners

Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in...

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Main Authors: Cooper, Joel, Fox, Randall, Loeprick, Jan, Mohindra, Komal
Format: Book
Language:English
en_US
Published: Washington, DC: World Bank 2016
Subjects:
Online Access:http://hdl.handle.net/10986/25095
id okr-10986-25095
recordtype oai_dc
spelling okr-10986-250952021-04-23T14:04:28Z Transfer Pricing and Developing Economies : A Handbook for Policy Makers and Practitioners Cooper, Joel Fox, Randall Loeprick, Jan Mohindra, Komal TP TRANSFER PRICING TRANSFER MISPRICING TAX REVENUE TRANSFER PRICING REGULATION TAX REFORM IN DEVELOPING COUNTRIES ARM'S LENGTH PRINCIPLE TAXATION OF MULTINATIONALS FINANCING FOR DEVELOPMENT BEPS BASE EROSION AND PROFIT SHIFTING DOMESTIC RESOURCE MOBILIIZATION Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate. 2016-09-28T17:14:18Z 2016-09-28T17:14:18Z 2016 Book 978-1-4648-0969-9 http://hdl.handle.net/10986/25095 English en_US Directions in Development--Public Sector Governance CC BY 3.0 IGO http://creativecommons.org/licenses/by/3.0/igo/ World Bank Washington, DC: World Bank Publications & Research Publications & Research :: Publication
repository_type Digital Repository
institution_category Foreign Institution
institution Digital Repositories
building World Bank Open Knowledge Repository
collection World Bank
language English
en_US
topic TP
TRANSFER PRICING
TRANSFER MISPRICING
TAX REVENUE
TRANSFER PRICING REGULATION
TAX REFORM IN DEVELOPING COUNTRIES
ARM'S LENGTH PRINCIPLE
TAXATION OF MULTINATIONALS
FINANCING FOR DEVELOPMENT
BEPS
BASE EROSION AND PROFIT SHIFTING
DOMESTIC RESOURCE MOBILIIZATION
spellingShingle TP
TRANSFER PRICING
TRANSFER MISPRICING
TAX REVENUE
TRANSFER PRICING REGULATION
TAX REFORM IN DEVELOPING COUNTRIES
ARM'S LENGTH PRINCIPLE
TAXATION OF MULTINATIONALS
FINANCING FOR DEVELOPMENT
BEPS
BASE EROSION AND PROFIT SHIFTING
DOMESTIC RESOURCE MOBILIIZATION
Cooper, Joel
Fox, Randall
Loeprick, Jan
Mohindra, Komal
Transfer Pricing and Developing Economies : A Handbook for Policy Makers and Practitioners
relation Directions in Development--Public Sector Governance
description Recent years have seen unprecedented public scrutiny over the tax practices of Multinational Enterprise (MNE) groups. Tax policy and administration concerning international transactions, aggressive tax planning, and tax avoidance have become an issue of extensive national and international debate in developed and developing countries alike. Within this context, transfer pricing, historically a subject of limited specialist interest, has attained name recognition amongst a broader global audience that is concerned with equitable fiscal policy and sustainable development. Abusive transfer pricing practices are considered to pose major risk to the direct tax base of many countries and developing countries are particularly vulnerable because corporate tax tends to account for a larger share of their revenue. This handbook is part of the wider WBG engagement in supporting countries with Domestic Resource Mobilization (DRM) by protecting their tax base and aims to cover all relevant aspects that have to be considered when introducing or strengthening transfer pricing regimes. The handbook provides guidance on analytical steps that can be taken to understand a country’s potential exposure to inappropriate transfer pricing (transfer mispricing) and outlines the main areas that require attention in the design and implementation of transfer pricing regimes. A discussion of relevant aspects of the legislative process, including the formulation of a transfer pricing policy, and the role and content of administrative guidance, is combined with the presentation of country examples on the practical application and implementation of the arm’s length principle and on running an effective transfer pricing audit program. Recognizing the importance of transfer pricing regulation and administration for the business environment and investor confidence, this handbook aims to balance the general objective of protecting a country’s tax base and raising additional revenue with investment climate considerations wherever appropriate.
format Book
author Cooper, Joel
Fox, Randall
Loeprick, Jan
Mohindra, Komal
author_facet Cooper, Joel
Fox, Randall
Loeprick, Jan
Mohindra, Komal
author_sort Cooper, Joel
title Transfer Pricing and Developing Economies : A Handbook for Policy Makers and Practitioners
title_short Transfer Pricing and Developing Economies : A Handbook for Policy Makers and Practitioners
title_full Transfer Pricing and Developing Economies : A Handbook for Policy Makers and Practitioners
title_fullStr Transfer Pricing and Developing Economies : A Handbook for Policy Makers and Practitioners
title_full_unstemmed Transfer Pricing and Developing Economies : A Handbook for Policy Makers and Practitioners
title_sort transfer pricing and developing economies : a handbook for policy makers and practitioners
publisher Washington, DC: World Bank
publishDate 2016
url http://hdl.handle.net/10986/25095
_version_ 1764458362611695616