TRANSFER PRICING MANUAL (2nd Ed.)

TRANSFER PRICING MANUAL (2nd Ed.)

Author: Piergiorgio Valente

The “Transfer Pricing Manual” (II Edition, pp. 3400) is a helpful tool that provides professionals and scholars with accurate and rigorous answers – from both, a legal-economic perspective as well as a hands-on approach – on complex issues involving intercompany transfer prices.
The Manual examines the Transfer Pricing topic in detail, by focusing on the most significant aspects. In particular, it provides an analytical picture that thoroughly reviews transfer pricing regulations in addition to all other information that might be necessary as a helpful guideline regarding operating issues that might derive from the application thereof. From this perspective, the Volume addresses both those who have to deal with the subject for academic and/or didactic purposes as well as those who are faced with problem-solving issues within a technical-professional context.
This second edition has the special feature to delve into certain specific themes that are treated comprehensively with respect to the first edition.
The text affords an in-depth examination of themes such as Transfer Pricing documentation duties pursuant to Italian legislation, Transfer Pricing regime proposals in developing Countries, EC and international procedures for settling international controversies, procedures relating to the determination of income allocation to PEs, intercompany loans, Transfer Pricing determination methods, intangibles, intercompany services, functional and comparability analyses as well as CCCTB.

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SAN MARINO: Taxation in International Treaties

SAN MARINO: Taxation in International Treaties

Author: Piergiorgio Valente

Bilateral treaties against double taxation represent a topical theme for current and future international tax scenarios.
Within a global competitive arena, the safeguard of income flows by the Tax Authorities assumes a particularly significant role as to the collateral tax planning and international arbitrage opportunities for taxpayers.
In such a context, knowledge of such Treaty instrument acquires strategic importance for economic operators investing abroad.
The International Tax Treaties Volume, at its sixth edition, has been representing for the past fifteen years a point of reference for specialized readers.

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