Description
An overarching look at transfer pricing regimes in Asia-Pacific countries and what they mean for foreign businesses A comprehensive guide for companies doing business globally, Asia-Pacific Transfer Pricing Handbook explains the policies and practices that Asia-Pacific countries employ with regards to taxing foreign businesses. The only book that analyzes and guides companies through the often complex transfer pricing rules in place in Asian-Pacific nations, the book explains how authorities in fifteen countries, including ASEAN, India, New Zealand, Japan, and South Korea, tax any company doing business within their borders. Helping foreign companies to properly price their goods and services for global markets, providing defenses for transfer pricing audits, explaining standards for creating comparables that multijurisdictional tax administrations will accept, explaining documentation requirements and timing issues, and creating awareness about inadvertently becoming a permanent establishment, Asia-Pacific Transfer Pricing Handbook is an essential resource for doing business abroad. * Provides comprehensive, accessible information on transfer pricing in Asia-Pacific countries * Covers fifteen Asia-Pacific countries, including all ASEAN countries, giving readers unparalleled exposure to the different transfer pricing arrangements across the region * Explains how companies doing business abroad should price their goods and services for global markets to remain in accordance with the law A complete and comprehensive guide to transfer pricing and its implications for firms and accountants operating in the Asia-Pacific region, Asia-Pacific Transfer Pricing Handbook explains everything foreign companies need to know about doing business abroad. Preface xxi PART ONE: COUNTRY-BY-COUNTRY ANALYSIS 1 Chapter 1 Introduction 3 Chapter 2 Australia’s Risk Assessment Transfer Pricing Approach 7 Chapter 3 Profit Attribution for a Dependent Chapter 4 Australia’s Advance Pricing Arrangement Program 49 Chapter 5 China Implements Transfer Pricing Procedures 55 Chapter 6 Reporting Related Party Transactions in China 105 Chapter 7 Hong Kong Advance Ruling Cases: Taxability of Profits 121 Chapter 8 Hong Kong Transfer Pricing Guidelines 143 Chapter 9 Hong Kong Challenges Abusive Tax Schemes 175 Chapter 10 Winning Hong Kong’s Landmark Transfer Pricing Case 185 Chapter 11 Transfer Pricing Litigation in India 205 Chapter 12 PE Issues Impact Indian Transfer Pricing 217 Chapter 13 Taxation of Travel Services in India 239 Chapter 14 Transfer Pricing in Indonesia 247 Chapter 15 Japan’s Directive on Transfer Pricing Operations 251 Chapter 16 Selecting the Arm’s Length Price in Japan 289 Chapter 17 Applying Japanese Intangible Transfer Pricing Methods 327 Chapter 18 Japanese Profi t Split Transfer Pricing Methods 345 Chapter 19 Japanese Guidelines Address Diverse Transfer Pricing Issues 373 Chapter 20 Malaysia Advance Ruling Guidelines 387 Chapter 21 Malaysia Transfer Pricing Guidelines 401 Chapter 22 New Zealand Transfer Pricing Developments 439 Chapter 23 Philippine Transfer Pricing Regulations 457 Chapter 24 Singapore Implements Advance Chapter 25 Singapore Transfer Pricing Consultation Process 475 Chapter 26 Singapore Transfer Pricing Guidelines 481 Chapter 27 Singapore Transfer Pricing Guidelines for Related Party Loans and Services 493 Chapter 28 South Korea Transfer Pricing 507 Chapter 29 Sri Lanka Transfer Pricing 527 Chapter 30 Taiwan Transfer Pricing 539 Chapter 31 Thailand Transfer Pricing 547 Chapter 32 Vietnam Transfer Pricing 559 PART TWO: ADVANCED APPLICATIONS 565 Chapter 33 Services Transfer Pricing in Hong Kong and in Singapore 567 Chapter 34 Permanent Establishment Parameters: Hong Kong versus India 585 Chapter 35 Pacific Tax Administrators Coordinate Transfer Pricing Documentation 591 Chapter 36 Shared Services and Cost Pooling Arrangements in the United States and Singapore 605 Chapter 37 South Korea-Japan Bilateral Investment Treaty 623 Chapter 38 China-Taiwan Trade 629 Chapter 39 Malaysia-Singapore Allocation Keys 643 Chapter 40 Permanent Establishment Parameters 659 About the Authors 671 Index 673
