Transfer Pricing Handbook: Guidance for the OECD Regulations

PART ONE: BASIC TRANSFER PRICING STANDARDS Look at the basic OECD transfer pricing standards, beginning with the arm's length principle and the limits to this arm's length range concept. Examine the OECD's safe harbors simplification approaches and to its safe harbor modifications. Analyze the global formulary apportionment alternative. Chapter 1: Introduction Chapter 2: Arm's Length Principle Chapter 3: Arm's Length Range Chapter 4: Safe Harbor Simplification Chapter 5: Modifying Safe Harbor Simplification Chapter 6: Global Formulary Apportionment PART TWO: TRANSFER PRICING METHODOLOGIES Look at the OECD's transfer pricing methodologies, recognizing the importance of the transactional profit split alternative, the application of the residual profit split, and limitations on the transactional net margin method. Examine profit indicators and other transfer pricing ramifications. Chapter 7: Transactional Profit Split Measures Chapter 8: Profits Split Illustrations Chapter 9: Residual Profit Split Examples Chapter 10: Transactional Net Margin Method Chapter 11: Selecting Profit Indicators Chapter 12: Selecting Transfer Pricing Methods PART THREE: COMPARABILITY ANALYSIS Take a comprehensive look at comparability analysis, examining how the specifics of the comparability process and comparability analysis techniques, as well as the timing issues that arise in assessing comparability. Chapter 13: How Comparability Analysis Works Chapter 14: Comparability Techniques Chapter 15: Timing and Comparability PART FOUR: ADMINISTRATIVE APPROACHES Examine the OECD's administrative approaches. Look to audits and advance pricing agreement techniques, and examine the monitoring process itself. Chapter 16: Transfer Pricing Audits Chapter 17: Monitoring the Guidelines PART FIVE: ADVANCED OECD ANALYSIS Gain insight into advanced OECD analysis. Examine the documentation requirements, intangible properties, and services arrangements. Analyze cost contribution arrangements and business restructuring. Chapter 18: Documentation Requirements Chapter 19: Intangible Property Chapter 20: Services Arrangements Chapter 21: Cost Contribution Arrangements Chapter 22: Business Restructuring PART SIX: PUTTING THE GUIDELINES TO WORK Examine factual patterns we developed in Malaysia as compared to Singapore operations; and in Taiwan as compared to Chinese operations. Analyze techniques to reverse engineer the transfer pricing process. Chapter 23: Malaysia-Singapore Allocation Keys Chapter 24: China-Taiwan Trade Chapter 25: Reverse Engineering the Transfer Pricing Process PART SEVEN: CONNECTING TRANSFER PRICING AND PERMANENT ESTABLISHMENT Connect transfer pricing with permanent establishment under the OECD provisions. Chapter 26: Permanent Establishment Parameters Chapter 27: Focus on Permanent Establishment