-traditional methodologies, especially profit-split methodologies, in the US and Australia, and to a lesser extent by the OECD. These … on this trade. Both US and Australian tax practitioners have acknowledged that some of the most difficult transfer … transactions. The US final section 482 regulations , the OECD Guidelines and the Australian transfer pricing rulings all permit …

and expanding their documentation and penalty rules (such as the United States (US), Australia, Canada, the United Kingdom … Fiscal Committee is very close to that provided by the IRS." As Australia and the UK also closely follow the OECD Transfer … between UK, Australian and US APAs. This paper proposes to examine some of the advantages and disadvantages of APAs as seen by …

rules, and Australia has proved to be no exception. The Ernst & Young 2003 Global Transfer Pricing Survey , conducted … imposition of onerous penalties for non-compliance with these requirements. In the US, for example, it has been said that: In … additional tax and penalties being raised. Australia was in fact one of the first of the world's major economies to introduce …

Taxation law is national law. Therefore, every sovereign nation can use taxation law to subsidise and incentivise … possible form of regulations are the rules regarding patent boxes. This paper looks at the differences in international law and … scrutinises the taxation law in 10 European countries with regards to the taxation of patents and similar regulations to protect …

Taxation law is national law. Therefore, every sovereign nation can use taxation law to subsidise and incentivise … possible form of regulations are the rules regarding patent boxes. This paper looks at the differences in international law and … scrutinises the taxation law in 10 European countries with regards to the taxation of patents and similar regulations to protect …

service providers in the U.S., U.K., EU, Canada, and each of the 132 member jurisdictions of the OECD’s Global Forum, as well … as 8 million U.S. expats. In light of The Panama Papers, this book offers a timely and valuable contribution on the …