IFA: Secondary Adjustments and Related Aspects of Transfer Pricing Corrections: Secondary Adjustments and Related Aspects of Transfer Pricing Corrections

by International Fiscal Association (IFA)

Overview

This Seminar focused not only on the technical consideration of Secondary Aspects but also on the underlying philosophical question: namely, should secondary adjustments be employed at all and, if so, what are the appropriate limitations on their use?

While a 'corresponding adjustment' may be appropriate in order to avoid double taxation, other secondary adjustments, such as ‘conforming adjustments' and ‘reclassification of income' are more problematic.

The Panellists and audience were asked to consider the implications of secondary adjustments in the context of tax compliance, tax administration, and private contracts. Is it appropriate for the tax administrator to intervene in private transactions to the extent of ‘deeming' a capital contribution or ‘deeming' a dividend?

In this book you will be introduced to a labyrinth of potential adjustments that could flow from the primary transfer pricing adjustment. A glossary of terms is provided to assist the reader in sorting through the maze. You will learn about set-offs and corresponding adjustments as well as about secondary adjustments, such as reclassification of income. Following the outline are examples and diagrams that explicate the principles explained in the outline, as well as papers prepared by individual panellists.

Product Details

ISBN-13:	9789041101587
Publisher:	Wolters Kluwer
Publication date:	03/01/1996
Series:	IFA Congress Series Set
Pages:	80
Product dimensions:	6.14(w) x 9.21(h) x 0.17(d)

Table of Contents

Introductory Notes
Works of the OECD I; J. Owens
Works of the OECD II; D. Lütti
Allocation of Profits under Article 14
To Which Extent do Employees Assigned to a Subsidiary Constitute a Permanent Establishment of the Parent Company?
Appendix 1: The OECD Committee on Fiscal Affairs
Appendix 2: Outline on Article 14
Appendix 3: Outline on Employees as a Permanent Establishment
Appendix 4: The Origins of OECD Model Articles 7, 14 and 15

Editorial Reviews

Presents the material that was prepared by a panel of international tax experts to address the subject. They consider not only the technical aspects of secondary adjustments, but also the underlying philosophical question of whether there should be any at all and if so what appropriate limitations might be. They discuss a labyrinth of potential adjustments that could flow from the primary transfer pricing adjustment, as well as set-offs and corresponding adjustments. No index. Annotation c. Book News, Inc., Portland, OR (booknews.com)

Booknews