Michael Lang – författare

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.

Information Systems Development (ISD) progresses rapidly, continually creating new challenges for the professionals involved. New concepts, approaches and techniques of systems development emerge constantly in this field. Progress in ISD comes from research as well as from practice.

This conference will discuss issues pertaining to information systems development (ISD) in the inter-networked digital economy. Participants will include researchers, both experienced and novice, from industry and academia, as well as students and practitioners. Themes will include methods and approaches for ISD; ISD education; philosophical, ethical, and sociological aspects of ISD; as well as specialized tracks such as: distributed software development, ISD and knowledge management, ISD and electronic business / electronic government, ISD in public sector organizations, IOS.

Information Systems Development (ISD) progresses rapidly, continually creating new challenges for the professionals involved. New concepts, approaches and techniques of systems development emerge constantly in this field. Progress in ISD comes from research as well as from practice.

This conference will discuss issues pertaining to information systems development (ISD) in the inter-networked digital economy. Participants will include researchers, both experienced and novice, from industry and academia, as well as students and practitioners. Themes will include methods and approaches for ISD; ISD education; philosophical, ethical, and sociological aspects of ISD; as well as specialized tracks such as: distributed software development, ISD and knowledge management, ISD and electronic business / electronic government, ISD in public sector organizations, IOS.

"Mike, this is Kristin. Kelly and the girls were in a car accident," the recording from my answering machine says in the stillness of my home. I hold my breath and wait for the next line, telling me, ". . . but everyone is all right." It never comes.

Imagine parents with two young children, the husband recently laid off, saddled with a mortgage on a brand-new house, when the family''s minivan is hit and forced through an intersection by a reckless driver. Their lives are altered forever, but the family commits to each other through various hardships over fifteen years, encouraged when a pediatric neurologist calls their three-year-old daughter "the Miracle Child."

In The Miracle Child: Traumatic Brain Injury and Me, Kelly and Michael Lang share their alternating and unique thoughts over the days and years following the tragic car incident that fractured their family and their lives, revealing the power of persistence, faith, acceptance, and above all, the commitment of family.