Pricing Books [Page 15 of 151]

Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments.

With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed:

• what is transfer pricing and the purpose of transfer pricing rules;
• the arm’s length principle and its application;
• the consequences of a transaction not being in accordance with the arm’s length principle;
• the transfer pricing methods;
• the mechanisms to avoid and resolve disputes;
• the transfer pricing documentation;
• the attribution of profits to permanent establishments;
• the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings.

The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment. 

Pricing analytics uses historical sales data with mathematical optimization to set and update prices offered through various channels in order to maximize profit. With this outstanding contribution to this subject, you will learn just how to identify and exploit pricing opportunities in different business contexts. Each chapter looks at pricing from an economist's viewpoint beginning with the basic concept of pricing analytics and what type of data are needed to use this powerful science; the common assumptions regarding the customer population's willingness- to-pay are discussed along with the price-response functions that result from these assumptions; examples from several industries and organizations; dynamic pricing, with a special emphasis on the most common application--markdown pricing; the new field of customized pricing analytics, where a firm responds to a request-for-bids or request-for-proposals with a customized price response; and the relevant aspects of behavioral science to pricing. Additional examples include the asymmetry of joy/pain that customers feel in response to price decreases/increases.