Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.

This title was first published in 2003. Among the major challenges transition economies are facing is how to cope with globalization. Foreign direct investment (FDI) has proved the most dynamic (defensive and offensive) response, as an integration and network tool, yet outward FDI has so far been overlooked in research. The vitality of outward FDI as an entry mode to the global economy is discussed in this authoritative volume from various angles, beginning with the context of the development strategy and the transition process. The experiences of the Slovene way of internationalization are compared with those of other transition economies. Readers will learn about the size, geographical distribution, trends and sectoral allocation of such outward FDI (OFDI) as well as the major motives, barriers and problems. The book also responds to questions about the extent to which outward FDI is instrumental in development/transition, EU accession and competitiveness strengthening. Based on extensive empirical research and focused case studies, the volume provides valuable lessons for other EU candidate countries and transition economies, while managerial experiences in entering Central and Eastern European markets offer universal internationalization lessons.

This paper provides a comprehensive survey of pertinent issues on sovereign debt restructurings, based on a newly constructed database. This is the first complete dataset of sovereign restructuring cases, covering the six decades from 1950–2010; it includes 186 debt exchanges with foreign banks and bondholders, and 447 bilateral debt agreements with the Paris Club. We present new stylized facts on the outcome and process of debt restructurings, including on the size of haircuts, creditor participation, and legal aspects. In addition, the paper summarizes the relevant empirical literature, analyzes recent restructuring episodes, and discusses ongoing debates on crisis resolution mechanisms, credit default swaps, and the role of collective action clauses.

This work presents twelve case studies of foreign direct investment in Bulgaria, the Czech Republic, and Slovenia. The studies include major firms such as Skoda and Danone, as well as smaller ventures, and cover the same sectors for each country, thereby permitting useful comparisons and assessments of: the role of country, sector, technology, and firm-specific characteristics in determining the pattern and nature of foreign direct investment; the potential implications of FDI for the competitiveness of the investing firms; the impact of infusions of capital investments, technology, and managerial resources for the host economies; and the policy implications for host countries and relevant international institutions.

Corporate credit growth in China has been excessive in recent years. This credit boom is related to the large increase in investment after the Global Financial Crisis. Investment efficiency has fallen and the financial performance of corporates has deteriorated steadily, affecting asset quality in financial institutions. The corporate debt problem should be addressed urgently with a comprehensive strategy. Key elements should include identifying companies in financial difficulties, proactively recognizing losses in the financial system, burden sharing, corporate restructuring and governance reform, hardening budget constraints, and facilitating market entry. A proactive strategy would trade off short-term economic pain for larger longer-term gain.

Seventeen in a series of annual reports comparing business regulation in 190 economies, Doing Business 2020 measures aspects of regulation affecting 10 areas of everyday business activity.

This comprehensive book provides a clear analysis of the European Restructuring Directive, which aims to improve national frameworks governing business restructuring and insolvency as well as to provide debt relief for individuals. Gerard McCormack explores the key aspects of the Directive including the moratorium on litigation and enforcement claims against the financially-troubled business, the provision for new financing, the division of creditors into classes, the introduction of a restructuring plan and the rules for approval of the plan by a court or administrative authority.