Transfer Pricing and Value Creation

Series on International Tax Law, Volume 116
1. Auflage 2019
ISBN: 978-3-7073-4123-2
Verlag: Linde Verlag Wien

Buch, Englisch, Band 116, 572 Seiten, Format (B × H): 155 mm x 225 mm, Gewicht: 1000 g

Reihe: Schriftenreihe zum Internationalen Steuerrecht

Value Creation and its effects on Transfer Pricing and tax law

Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways.

Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.

Autoren/Hrsg.

Petruzzi, Raffaele

Tavares Esq., Romero J. S.

Fachgebiete

• Rechtswissenschaften Steuerrecht Internationales und Europäisches Steuer-, Bilanz- und Rechnungslegungsrecht

Über Autor(innen)

Petruzzi, Raffaele
Dr. Raffaele Petruzzi, LL.M. is managing director of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business) and an international tax advisor specializing in international corporate taxation and transfer pricing at L&P Global (Vienna) and at Ludovici Piccone & Partners (Milan).

Tavares Esq., Romero J. S.
A research associate and lecturer at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business). He is a Partner in the PwC Global Core Team (Global Tax Policy & Administration) specializing in Global Integrated Structuring and Value Chain Transformation and is the Leader of International Tax Services and Transfer Pricing at PwC in Brazil. He is also an adjunct Professor of International Tax Policy and Tax Law in São Paulo.