The Mind Maps available below present the complex U.S. transfer pricing rules and the OECD Model Treaty rules on topics of importance and interest to any professional with international dealings, in a convenient, illustrated, flow chart format. These maps were prepared by Prof. William Byrnes, Associate Dean, Walter H. & Dorothy B. Diamond International Tax & Financial Services Program, and update author of Foreign Tax & Trade Briefs.
Each Map communicates in context the concept's relevant related processes and issues and contains extensive links to further primary or analytical content.
The Mind Maps represent an excellent resource for users looking to gain an understanding of the topic at hand, as well as an efficient research roadmap to navigate to analytical resources for deeper information.
Specific topics addressed include:
OECD Model Tax Convention
Business profits
Capital Gains
Capital
Competent Authority Proceedings
Directors' Fees
Income
Interest
OECD Resident in Both Contracting States
Permanent Establishment
Royalties
Transfer Pricing
Accuracy Related Penalties
Activities Giving Rise to Transfer Pricing Issues
Adjustment Procedure
Allocation
Arms' Length Principle
Methods
Penalties
Record Keeping and Reporting
Related Parties
Relief from Double Taxation
Secondary Adjustments
Self-compliance
Sources of Law and Regulations
Substantial Understatement of Tax
Transfer Pricing Disputes
Types of Secondary Adjustments