Essays about: "Transfer Pricing"

Showing result 11 - 15 of 89 essays containing the words Transfer Pricing.

  1. 11. Impact and Adoption of Flexibility in a Rigid and Centralized Distribution Network : A Case Study on a Global Manufacturing Company

    University essay from KTH/Industriell Management; KTH/Industriell Management

    Keywords : Manufacturing and Distribution Network; Standardization; Centralization;

    Abstract : For manufacturing firms to succeed in the global marketplace it is important that they have an efficient supply chain that is well adapted to the characteristics of the products.This thesis explore the companies' challenge to adapt its supply chain to the characteristics of  heir products. READ MORE

  2. 12. How can the proposed changes to the OECD tax model convention in action 1 and action 7 counter the issue of an artificial avoidance of a PE status?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Maria Wettersten; [2016]
    Keywords : Permanent establishment; BEPS action 1; BEPS action 7; artificial avoidance; Law and Political Science;

    Abstract : The purpose of this thesis is to clarify how, according to BEPS action 1 and action 7, can the amendments of the “specific activity exemptions” in article 5 paragraph 4 of the OECD Model Tax Convention on Income and Capital (the model convention) counter the issue of an artificial avoidance of a PE status. The main issues that are connected to the concept of a permanent establishment are artificial avoidance of the status of a permanent establishment, the use of transfer pricing rules in order to artificially allocate the profits of a permanent establishment to low tax states and finally that some enterprises that operate within the digital economy can avoid the status of a permanent establishment due to the lack of physical presence. READ MORE

  3. 13. Transfer Pricing Treatment of Transactions with Hard-to-Value Intangibles: Is BEPS Action 8 Based on the Arm’s Length Principle?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Oleh Fedusiv; [2016]
    Keywords : Transfer Pricing; Intangibles; Hard-to-Value Intangibles; BEPS; Arm’s Length Principle; Law and Political Science;

    Abstract : This master’s thesis analyses BEPS Action 8 recommendations in relation to transactions with hard-to-value intangibles. OECD has developed them with a view to ensure that transfer pricing outcomes of transactions with hard-to-value intangibles are aligned with value creation. READ MORE

  4. 14. Country-by-Country Reporting: A study on how Swedish MNEs prepare for the new transfer pricing documentation requirement

    University essay from Handelshögskolan i Stockholm/Institutionen för redovisning och finansiering

    Author : Michaela Appelkvist; Olivia Jansson; [2016]
    Keywords : Country-by-Country Reporting; BEPS Action Plan; Transfer Pricing; Management Control Systems; Stakeholder Management;

    Abstract : This paper employs a hybrid methodological approach to study the impact of the steps taken to comply with the new transfer pricing documentation requirement, Country-by-Country (CbC) reporting, on the management control system (MCS) in a Swedish multinational enterprise (MNE). Based on the empirical case study findings and the results from the industry survey, we find that there are inconsistencies between how transfer pricing policies are developed according to the arm's length principle (ALP) and how the outcome from those policies are documented in the common CbC report model template developed by the OECD. READ MORE

  5. 15. BEPS Action plan 13 in the light of confidentiality

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Filippa Håkansson; [2016]
    Keywords : BEPS; Action 13; CbC-reporting; OECD; Transfer Pricing; Transfer Pricing Documentation; Transparency; Law and Political Science;

    Abstract : OECD introduced 15 Action plans as part of the BEPS-project in 2014 in their work to combat base erosion and profit shifting (BEPS). Action plan 13 provides for a re-examined transfer pricing documentation and a new Country-by-country-reporting. The CbC-reporting is to be included in a three-tired approach including a master-file and a local-file. READ MORE