Essays about: "Transfer Pricing"

Showing result 16 - 20 of 85 essays containing the words Transfer Pricing.

  1. 16. Attribution of Free Capital and Interest Expenses to a Permanent Establishment under the ‘Authorised OECD Approach’ for non-financial Enterprises What is the Impact of Interest Attribution on the Allocation of Profits under the new Approach?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Aaron Kindich; [2014]
    Keywords : International Tax Law; Permanent Establishment; OECD; Authorised OECD Approach; AOA; Functionally Separate Entity Approach; Allocation of Profits; Law and Political Science;

    Abstract : This thesis aims at analysing and discussing the rules and opportunities of using permanent establishment within financial structures. Financing structures between related parties can be seen as one of the most common tax planning tools for MNE´s. READ MORE

  2. 17. Tax Motivated Transfer Pricing

    University essay from Lunds universitet/Företagsekonomiska institutionen

    Author : Shirley Ye Ekström; Loris Dall; Darja Nikolajeva; [2014]
    Keywords : Business and Economics;

    Abstract : Multinational Corporations (MNCs) or Multinational Enterprises (MNEs) are of great importance in the global economy. A great amount of international trade is either between multinational corporations or within a multinational corporation, which is called intra-firm trade. Therefore, intra-firm trade is also of importance in the global economy. READ MORE

  3. 18. 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

  4. 19. 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

  5. 20. 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