Essays about: "Transfer Pricing Adjustments"

Showing result 1 - 5 of 16 essays containing the words Transfer Pricing Adjustments.

1. 1. Transfer pricing adjustments derived from state aid cases - Are corresponding adjustments mandatory for EU Member States?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Ruby Michelle De Fátima Rojas Ixtacuy; [2022]
   Keywords : Corresponding adjustments; State Aid; Transfer pricing; Dispute Resolution Mechanisms; Arbitration; OCDE; double economic taxation; EU Member States; EU tax law; Tax Law; Law and Political Science;

   Abstract : When an EU MS executes a state aid recovery decision, specifically those cases regarding Advance Pricing Agreements (APAs), an economic double taxation issue and a potential TP dispute may arise, which could be generated by the need for the application of a corresponding adjustment. In any case, each jurisdiction has the discretion to determine if the application of a corresponding adjustment should be made. READ MORE

3. 2. Secondary Transfer Pricing Adjustments: Interpretation Challenges within the EU and International Perspectives

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Andrii Falendysh; [2021]
   Keywords : tax law; transfer pricing; secondary transfer pricing adjustments; interpretation; PSD; parent-subsidiary directive; OECD MC; constructive dividends; constructive interest; constructive capital injection; secondary transaction; Law and Political Science;

   Abstract : This master thesis elaborates on the issues of the secondary transfer pricing adjustments that are common yet not regulated in an efficient manner by the states. The core problem of the double taxation issues to follow is the unwillingness of the states to accept the administrative tax decisions of each other in such sensitive fields as transfer pricing. READ MORE

4. 3. Compensating adjustments - An international perspective

   University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

   Author : Oskar Paladini Söderberg; [2018]
   Keywords : Skatterätt; finansrätt; fiscal law; transfer pricing; compensating adjustments; economic double taxation; Law and Political Science;

   Abstract : The purpose of this essay is to investigate if there exist any differences in the handling of compensating adjustments between Sweden and the UK and why these differences exist together with what consequences it may bring. Differences were identified, such as the fact that the UK only allows for compensating adjustments in an upward direction whilst Sweden accepts adjustments in both directions. READ MORE

5. 4. The Commission Proposal for a Directive on Double Taxation Dispute Resolution Mechanisms: Will it resolve the remaining double taxation issues within the EU?

   University essay from Lunds universitet/Juridiska institutionen

   Author : Jiawen Xi; [2017]
   Keywords : Double taxation; European Union; Double taxation resolution; Arbitration Convention; ATAD; Law and Political Science;

   Abstract : Double taxation has been widely accepted that constitutes an obstacle to the functioning of the single market. The European Union has adopted some uniform measures to have double taxation eliminated, for example, the Parent-Subsidiary Directive and the Interest-Royalty Directive. READ MORE

6. 5. Impact of Transfer Pricing Adjustments on VAT Liabilities

   University essay from Lunds universitet/Juridiska institutionen

   Author : Anna Baranowska; [2016]
   Keywords : Transfer Pricing; Transfer Pricing Adjustments; VAT; taxable transactions; taxable amount; corporate income tax; indirect taxation; Law and Political Science;

   Abstract : The paper analyses whether different types of transfer pricing adjustments could have impact on VAT liabilities. It assesses different nature of adjustments (primary, secondary, corresponding, compensating) and whether they could be seen either as a separate taxable transaction from the VAT perspective or as an alternation of the taxable amount fot the VAT purpose. READ MORE