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Global Transfer Pricing: Principles and Practice

Thought leadership in the post-BEPS era

Now in its fourth edition, Deloitte's Global Transfer Pricing book continues to provide a comprehensive guidance for one of the most important areas of business taxation.

Deloitte’s Global Transfer Pricing book is widely used by transfer pricing professionals, economists, lawyers, academics, tax authorities and everyone else who is interested in transfer pricing.

How to effectively manage transfer pricing risks and compliance with transfer pricing rules is one of the recurring challenges for taxpayers. Deloitte’s Global Transfer Pricing book offers readers an overview of transfer pricing as it is practised today, including the 2017 changes to the OECD Transfer Pricing Guidelines following the Base Erosion and Profit Shifting (BEPS) initiative which brought about multiple changes and led to a renewed focus of tax authorities on transfer pricing.

In addition to an introduction to transfer pricing, the book describes the elements that can help to achieve the successful implementation of transfer pricing models in global multinationals, how to monitor intercompany transactions to implement transfer pricing policies and how to create effective transfer pricing documentation. The book includes transfer pricing considerations for financial transactions, an area which can sometimes be overlooked.

Some of the most important updates in the fourth edition:

  • An update on the implementation of OECD BEPS recommendations, including artificial avoidance of permanent establishments and prevention of treaty abuse
  • Implementation of transfer pricing documentation and country-by-country reporting
  • Additional case law commentary 

Chapter updates include:

  • Chapter 5 'Financing' has been updated to include commentary on the OECD discussion draft on transfer pricing aspects of financial transactions, including treasury functions, guarantee fees and captive insurance
  • Chapter 7 'Profit Split' has been expanded to cover new guidance on profit split and the recent trend towards the use of this transfer pricing methodology
  • The 'UK' chapter includes new content on interest restriction rules and transfer pricing, penalties for non-compliance, rules governing the conduct of transfer pricing audits and also Brexit considerations
  • A new chapter has been added on 'The Attribution of Profits to Permanent Establishments' to cover Articles 7 and 9 of the OECD Model Tax Treaty
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