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Transfer pricing and corporate taxation

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Nội dung chi tiết: Transfer pricing and corporate taxation

Transfer pricing and corporate taxation

Transfer Pricing and Corporate TaxationElizabeth KingTransfer Pricing and Corporate TaxationProblems, Practical Implications and Proposed Solutions0 S

Transfer pricing and corporate taxationSpringerElizabeth KingBeecher Consulting. LLC9 Beecher Road Brookline. MA 02445 USAwww.beecherconsultinggroup.comISBN: 978-0-387-78182-2 e-ISBN: 978-0

-387-78183-9DOI: 10.1007/978-0-387-78183-9Library of Congress Control Number: 2008937177©■ Springer Science+Business Media. LLC 2(XWAll rights reserve Transfer pricing and corporate taxation

d. This work may not be translated or copied in whole or in part without the written permission of the publisher (Springer Scicncc+Busincss Media, LLC

Transfer pricing and corporate taxation

, 233 Spring Street, New York, NY HMM3, USA), except for brief excerpts in connection with reviews or scholarly analysis. Use in connection with any f

Transfer Pricing and Corporate TaxationElizabeth KingTransfer Pricing and Corporate TaxationProblems, Practical Implications and Proposed Solutions0 S

Transfer pricing and corporate taxationeloped is forbidden.The use in this publication of trade names, trademarks, service marks, and similar terms, even if they arc not identified as such,

is not to be taken as an expression of opinion as to whether or not they are subject to proprietary rights.Printed on acid-free paperspringcr.comFor Transfer pricing and corporate taxation

Ella, an extraordinary person and a wonderful daughterAcknowledgementsIhave worked with many people—clients, attorneys and international examiners, fe

Transfer pricing and corporate taxation

llow transfer pricing economists and others—over the years, all of whom have contributed greatly to my understanding of the issues addressed in this b

Transfer Pricing and Corporate TaxationElizabeth KingTransfer Pricing and Corporate TaxationProblems, Practical Implications and Proposed Solutions0 S

Transfer pricing and corporate taxationo thank several people for their extremely helpful and insightful comments on this manuscript. Confidentiality constraints prevent me from mentioning

anyone by name. Finally, my profound thanks to Marianne Burge, in memoriam. for her mentoring and personal friendship.USAElizabeth KingviiContents1Int Transfer pricing and corporate taxation

roduction ...................................................... 1Part I Economic and Accounting Rates and Concepts ShouldNot be Conflated2Economic vs

Transfer pricing and corporate taxation

. Accounting Profit Rates............................... 73Overview and Critique of Existing Transfer Pricing Methods........ II3.1Comparable Profits

Transfer Pricing and Corporate TaxationElizabeth KingTransfer Pricing and Corporate TaxationProblems, Practical Implications and Proposed Solutions0 S

Transfer pricing and corporate taxationplied........... 143.1.3Underlying Economic Rationale......................... 143.1.4Critique of Economic Reasoning........................ 15

Transfer Pricing and Corporate TaxationElizabeth KingTransfer Pricing and Corporate TaxationProblems, Practical Implications and Proposed Solutions0 S

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