The Transactional Net Margin Method

Nathalie Boquist

ISBN 10: 3838342070 / ISBN 13: 9783838342078

Editore: LAP LAMBERT Academic Publishing Jul 2010, 2010

Riguardo questo articolo

Neuware -The transactional net margin method was established in the OECD Transfer Pricing Guidelines of 1995 and was included to solve differences between OECD Member Countries, but since many countries have been against the method, there does still exist a risk of double taxation. OECD recommends the transactional net margin method to be used only if none of the traditional methods can be used. OECD Member Countries are encouraged to follow the OECD Transfer Pricing Guidelines when pricing transactions in practice, but they are not legally binding. The purpose of this book is to analyse whether the transactional net margin method is used as a last resort method in practice and to determine whether the method should hold the status of last resort in the future.The book provides an analysis of the differences between theory and practice and discusses whether the status of TNMM should change to one of greater parity with competing practices which can be useful for many companies.Books on Demand GmbH, Überseering 33, 22297 Hamburg 72 pp. Englisch.

Codice articolo 9783838342078

Dati bibliografici

• Titolo: The Transactional Net Margin Method
• Editore: LAP LAMBERT Academic Publishing Jul 2010
• Data di pubblicazione: 2010
• Lingua: Inglese
• ISBN 10: 3838342070
• ISBN 13: 9783838342078
• Rilegatura: Taschenbuch
• Condizione: Neu

Descrizione articolo

Riassunto

The transactional net margin method was established in the OECD Transfer Pricing Guidelines of 1995 and was included to solve differences between OECD Member Countries, but since many countries have been against the method, there does still exist a risk of double taxation. OECD recommends the transactional net margin method to be used only if none of the traditional methods can be used. OECD Member Countries are encouraged to follow the OECD Transfer Pricing Guidelines when pricing transactions in practice, but they are not legally binding. The purpose of this book is to analyse whether the transactional net margin method is used as a last resort method in practice and to determine whether the method should hold the status of last resort in the future.The book provides an analysis of the differences between theory and practice and discusses whether the status of TNMM should change to one of greater parity with competing practices which can be useful for many companies.

L'autore

Studied international law of taxation at Jonkoping International Business School, Current position: Tax Agent at The Swedish Tax Agency.