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Global Transfer Pricing Solutions 2004

Global Transfer Pricing Solutions 2004

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Global Transfer Pricing Solutions: 2004 covers the major transfer pricing regimes around the world with in-depth discussion and analysis of such topics as proactive transfer pricing management of post-merger integrations, e-commerce and intellectual property.

The report covers a wide range of tools and techniques relevant to transfer pricing in Asia, Europe, Latin America, Russia/Eurasia, and North America.

Coverage includes:

* A global, OECD, and country review of cost contribution agreements (CCAs)
* Increasing profitability through enterprise price optimization (EPO)
* Transfer pricing documentation requirements for global businesses
* Transfer pricing and the R&D conundrum
* Comparisons of transfer pricing rules in Latin America and the U.S.; tax treatment of intangibles
* Use of unilateral and bilateral advance pricing agreements (APAs)
* Sourcing income to preserve the use of credits and carryovers
* Migration of IP rights: From a Transfer Pricing Perspective
* Intellectual Property: the Transfer Pricing and R&D Conundrum
* Recent Circulars in China Make Important Changes in Transfer Pricing
* UK Tax Reform Proposals on Transfer Pricing and Thin Capitalization
* Argentina's 2003 Transfer Pricing Amendments
* Transfer Pricing Control Mechanisms in Brazil
* Russia Transfer Pricing: Proposed Amendments and Court Rulings
* New Transfer Pricing Rules for Services, Intangible Property: Implications for US Multinationals & Others
* Wider Application of Transfer Pricing Methods Affects International Treasury Management
* Enterprise Price Optimization: Increasing Profitability
* Hungarian Transfer Pricing Regulations
* Sourcing Income to Preserve the Use ofCredits and Carryovers
* Transfer Pricing Regulations in Peru
* The APA Program Annual Report