National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies.
Economic and Accounting Rates and Concepts Should Not be Conflated.- Economic vs. Accounting Profit Rates.- Overview and Critique of Existing Transfer Pricing Methods.- Alternative and Supplementary Approaches to Transfer Pricing.- Some Alternative Approaches to Transfer Pricing.- Case Studies.- Intercompany Sale of Diamonds.- Intercompany Sale of Medical Devices.- Performance of Intercompany Services.- Replication of Internet-Based Business Model.- Sale of Assets with Embedded Intellectual Property.- Provision of CDN Services to Third Parties.- Global Trading of Commodities.- Decentralized Ownership of Intellectual Property.- Conclusions.- Concluding Observations.
From the reviews: "The book of Elizabeth King is written for the benefit of tax practitioners. The focus is on the various transfer pricing cases. The case studies reflect in particular the US views as for example the FIN 48 specifications. We recommend this book to tax advisors and inhouse tax specialists handling transfer pricing aspects in particular related to the US." (Steuern-buecher, September, 2012)