Giammarco Cottani – författare

This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines.

As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following:

extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics;

specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India;

detailed presentation of the use of new technologies by both taxpayers and tax authorities; and

further in-depth analysis of transfer pricing’s interaction with various fields of law.

With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.

This is Part Two of a crucially significant two-volume set on the nature of transfer pricing that fully elucidates how the growing body of applicable rules works in practice. The preceding volume, subtitled General Topics and Specific Transactions, focused on basic principles and specialized topics. This volume enlarges the scope of the first volume, particularly concerning industry specifics, regional considerations, the use of new technologies, and the intersection between transfer pricing rules and other disciplines.

As in the first volume, stakeholding contributors from government, multinational companies, international organizations, advisory groups, and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules. With numerous examples and relevant international judicial precedents, the authors augment the first volume in such ways as the following:

extended analysis of particular business sectors, including automotive, banking, consumer goods, insurance, IT, oil and gas, and pharmaceutics;

specific jurisdictional coverage of the United States, the European Union, Brazil, China, and India;

detailed presentation of the use of new technologies by both taxpayers and tax authorities; and

further in-depth analysis of transfer pricing’s interaction with various fields of law.

With this authoritative source of practical guidance, advisors, in-house practitioners, government officials, and academics worldwide will have all the details they need to move forward in tackling the complex aspects of the current transfer pricing environment.

Fundamentals of Transfer Pricing

Volume 1: Principles and Practice

Edited by Raffaele Petruzzi, Giammarco Cottani & Michael Lang

Transfer pricing is one of the most important and complex topics in international taxation. Recognising its significance, most countries in the world have introduced transfer pricing rules in their domestic tax systems. This book, the first of a three-volume series, explains in a clear and simple manner the most important transfer pricing topics, with a collection of incisive and wide-ranging perspectives from representatives of academia, tax law practice, multinational companies, advisory groups, national tax authorities, and international organisations from all over the globe.

The contributions collectively offer a comprehensive guide to the practical application of transfer pricing rules, covering various aspects as the following:

         introduction to transfer pricing;

         accurate delineation and recognition of actual transactions;

         transfer pricing methods;

         comparability analysis;

         transfer pricing audits and litigation;

         administrative approaches to preventing and resolving transfer pricing disputes;

         transfer pricing documentation;

         attribution of profits to permanent establishments;

         transfer pricing and specific transactions;

         use of new technologies in transfer pricing; and

         interplay between transfer pricing and other rules.

This book delves into both foundational concepts and emerging trends in transfer pricing, providing readers with the tools to understand its dynamic application in real-world scenarios. By analysing examples, case studies, and the implications of recent judicial precedents, it bridges the gap between fundamental principles and practical implementations.

The application of transfer pricing legislation remains one of the most challenging tasks for taxpayers and tax authorities around the world. With this comprehensive source of practical guidance, tax lawyers, in-house tax counsels, government officials, academics, advisory firms, and the business community worldwide will have all the support they need to move forward in tackling this complex aspect of the current tax environment.