J. Elliot - International Transfer Pricing: A Survey of Cross-Border Transactions (CIMA Research)
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International Transfer Pricing: A Survey of Cross-Border Transactions (CIMA Research)
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Following legislative changes, this report sheds light on the contentious area of international transfer pricing (ITP) by moving away from primary tax focus. By examining one specific intra-group, cross-border transaction between 12 MNEs, the resulting micro-level of analysis provides a qualitative, in-depth understanding of ITP within the financial services, manufacturing and service sectors.
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International Transfer Pricing : A Study of Cross-border Transactions
author
:
Elliott, J.; Emmanuel, Clive R.
publisher
:
CIMA Publishing
isbn10 | asin
:
1859713467
print isbn13
:
9781859713464
ebook isbn13
:
9780585328164
language
:
English
subject
Transfer pricing, International business enterprises--Taxation.
publication date
:
2000
lcc
:
HD62.45.E45 2000eb
ddc
:
336.243
subject
:
Transfer pricing, International business enterprises--Taxation.
Page i
International Transfer Pricing
A Study of Cross-border Transactions
J Elliott
University of Southampton
C R Emmanuel
University of Glasgow
The Chartered Institute of Management Accountants
This publication arises from the research project 'A field study investigation of international transfer pricing (ITP) policy in twelve organisations' which was funded with a research grant from the CIMA Research Foundation. The award of a Research Foundation grant, and the publication of findings in this format, indicates that the recipient has successfully passed two separate peer review processes, which also involved practitioner assessors. The views expressed in this publication are the authors' own, and do not necessarily represent those of CIMA.
Page ii
Acknowledgements
We should like to thank the Research Foundation of the Chartered Institute of Management Accountants for supporting this project. We also wish to record our gratitude to the managers and directors who spared the time to participate in the fieldwork and who discussed their international transfer-pricing policies in detail. The researchers are also indebted to Mrs Veda Smillie who painstakingly transformed numerous files and notes into a legible and articulate report.
Copyright CIMA 2000 First published in 2000 by: The Chartered Institute of Management Accountants 63 Portland Place London W1N 4AB
ISBN 1 85971 346 7
The publishers of this book consider that it is a worthwhile contribution to discussion, without necessarily sharing the views expressed, which are those of the authors.
No responsibility for loss occasioned to any person acting or refraining from action as a result of any material in this publication can be accepted by the authors or publishers.
All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopying, recorded or otherwise, without the prior permission of the publishers.
Page iii
Contents
Executive Summary
v
The Significance of International Transfer Pricing
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