Essays about: "Transfer Pricing"

Showing result 16 - 20 of 80 essays containing the words Transfer Pricing.

  1. 16. The Side Effects of Transfer Pricing - A case study on a Swedish MNE

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

    Author : Diana Takács; Venus Shahriari; [2014]
    Keywords : Transfer pricing; Transfer pricing impact; HQ-Sub-unit relationship; Management control; Coercive versus Enabling;

    Abstract : This paper aims to investigate how transfer pricing (TP) impacts the major management control functions: organizing, planning, evaluating and rewarding (Chow et al., 1999) and if there is any difference in the perceived impact between sub-units in a TP tax compliant multinational enterprise (MNE). READ MORE

  2. 17. Implementation of a Funds Transfer Pricing model with stochastic interest rates

    University essay from Lunds universitet/Matematisk statistik

    Author : Fredrik Danielsson; [2014]
    Keywords : Mathematics and Statistics;

    Abstract : The subject of Funds Transfer Pricing (FTP) is widely known within the banking in- dustry, despite this there is a lack of consensus on how to allocate the costs and benets to the users and suppliers of liquidity. A common practice in nancial institutions, in particular before the nancial crisis, was to charge business units a liquidity charge that was based on the average or the historic cost of funds, which did not properly re ect the liquidity risk for each specic business unit. READ MORE

  3. 18. PE Threshold for Business Profits in E-Commerce Context-To what extent does the present Permanent Establishment threshold influence the taxation of Electronic Commerce cross-border transactions?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Petrit Ademi; [2014]
    Keywords : E-Commerce; PE threshold; Permanent Establishment; Article 5; Article 7; OECD; Source taxation; Business Profits; Law and Political Science;

    Abstract : Issues related to attribution of profits already exist in the traditional economic framework and are of a different nature, however these issues seem to become more bothersome in transactions conducted in e-commerce context, with an electronic economy. The matter is similar to the traditional economic problems in regard to transfer pricing adjustments; however these issues are much more complex due to the e-commerce nature, especially when considering the fact that multinational enterprises may gather data from different jurisdictions, and for different purposes, which makes the tracing of the source of the data highly complex. READ MORE

  4. 19. Transfer Pricing Documentation : - In Need Of A Harmonization?

    University essay from Högskolan i Jönköping/IHH, Rättsvetenskap; Högskolan i Jönköping/IHH, Rättsvetenskap

    Author : Richard Sandström; Puja Karimzadeh; [2014]
    Keywords : ;

    Abstract : In today's global world where internal cross-border transactions are made in a vast amount and thereby affect the economy to a large extent the area of transfer pricing has become more important than ever. Therefore the organization for economic co-operation and de-velopment (OECD) have started the base erosion and profit shifting project which aims to prevent the exploiting of gaps and differences of regulations in different states in cross-border transactions. READ MORE

  5. 20. Transfer Pricing: Entitlement to Intangible Related Returns

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Aleksandra Stojanova; [2013]
    Keywords : Transfer Pricing; Intangibles; Intangible related returns; Law and Political Science;

    Abstract : The entitlement to the income arising from the development and use or transfer of the intangible property within the MNE group members has been contentious issues for transfer pricing purposes. This paper aims to discuss and analyse the concept of entitlement to intangible related returns, considering the application of the arm’s length principle with regard to allocation of the benefits as provided within the Article 9 of the OECD MTC. READ MORE