Technical Editor: Gareth Green

Gain a comprehensive guide to transfer pricing theory and practice, from a global perspective.

The Transfer Pricing Manual gives you an authoritative practical overview from leading practitioners world-wide. 

Refer to the practical examples and expert guidance on how things are done in the "real" transfer pricing world.  Each chapter looks at the OECD guidelines relevant to that area and examines how they are reflected in practice.  Obtain essential insight and clarity with the expert solutions provided to typical problems that arise.  The Transfer Pricing Manual is invaluable for its day-to-day practical reference value.

Each topic is covered in a comprehensive and seamless manner for ease of reference.  This allows you to research specific transfer pricing queries instantly and accurately.   Authors are drawn from the key trading areas of Europe, the US and Asia to give a unique global perspective.  Practical and comprehensive, the Transfer Pricing Manual is your essential reference guide to transfer pricing theory and practice.

Contributors include: Ernst & Young, Deloitte, PwC, Ceteris, NERA, CMS Bureau Francis Lefebvre, Baker Tilly, Rabobank  and Transfer Pricing Solutions.

About the Authors 

Gareth Green runs independent UK transfer pricing boutique Transfer Pricing Solutions. He has extensive experience in transfer pricing, having worked virtually full-time in this area since 1995, primarily in the UK, but also in the United States and New Zealand. Before setting up TPS in January 2003, Gareth was a Director in Ernst & Young’s London transfer pricing group. Gareth has authored numerous articles on transfer pricing for various journals and has written chapters on transfer pricing for UK tax reference works. He is regularly named as one of the UK’s leading transfer pricing advisers.

Contents:

Foreword
Caroline Silberztein, Head of Transfer Pricing Unit, OECD, Paris

SECTION A

1. Introduction  
    Gareth Green Transfer Pricing Solutions, UK

2. Arm's length principle
    Koichiro Fujimori,  Deloitte Touche Tohmatsu, Tokyo

3. The transfer pricing methods
    Carsten Kratzer,  Baker Tilly, Germany

4. Focus on Profit Split Method
    Alexander Vögele, NERA Germany

5. Permanent establishments and profit apportionment
    Andrew Senior,  Rabobank, London

6. Practical issues in carrying out and implementing a
    transfer pricing study
    Dick De Boer, PwC, Amsterdam

7. Carrying out a transfer pricing analysis
    Leslie Prescott-Haar, Ernst & Young, New Zealand

SECTION B

8. Intra-group services
    Peter Male,  Director, Transfer Pricing Solutions, UK.

9. Intra-group finance
    Alfredo J.Urquidi, Marsh & McLennan, US

10. Intangibles/Intellectual Property
      Mike Heimert,  Ceteris, Chicago

11. Cost contribution arrangements and CSAs
      Stephane Gelin,  CMS Bureau Francis Lefebvre, Paris

SECTION C

12. Tax Planning using Transfer Pricing
      Dick Clark Deloitte, Washington DC

13. Eliminating double taxation: DTAs, APAs
      and Arbitration
      John Hobster,  Ernst & Young, London

SECTION D

14. Banking and Global Trading of Financial Instruments
      Sherif Assef, Ceteris, New York

15. Insurance and fund management
      Stephen Labrum,  Ernst & Young, London

16. Telecoms
      Anjali Bhasin and Ted Keen,  CRAI Washington
      and London

17. Professional services and Global Contracts
      Gareth Green Transfer Pricing Solutions, UK

18. Professional services and Global Contracts
      Molly Minnear, CRAI, Washington

Read the full contents here.

Full sample chapter

Read the full chapter, "Transfer pricing methods" by Carsten Kratzer here