Essays about: "Transfer Pricing"

Showing result 6 - 10 of 87 essays containing the words Transfer Pricing.

  1. 6. The Allocation of Residual Profits Deriving from Intangibles in a Transfer Pricing Context

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Fiona Gassauer-Fleissner; [2017]
    Keywords : Tax International Tax Law Transfer Pricing Intangibles Residual Profits BEPS Transfer Pricing Guidelines Arm s Length Formulary Apportionment; Law and Political Science;

    Abstract : After giving an introduction to the basics of transfer pricing with a focus on intangibles, this paper aims to establish the nature of residual profits and what needs to be considered when such profits are generated. It will become clear that residual profits are an economic concept rather than an element of tax law which is why, first, a connecting link needs to be found between these two disciplines. READ MORE

  2. 7. Hard to value intangibles from a Swedish perspective

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Håkan Vahlsten; [2017]
    Keywords : BEPS Action 8-10; Transfer Pricing; Arm s length principle; Arm s length distance; Inkomstskattelagen; Korrigeringsregeln; Intangibles; Hard To Value Intangibles; HTVI; Law and Political Science;

    Abstract : The purpose of this thesis is to study the work of the OECD presented in the Final BEPS-Report under Action 8 concerning hard to value intangibles in a Swedish context. Further, the OECD Model Tax Convention and its Commentaries are discussed in terms of their validity as a source of law in a Swedish perspective, or if there is a requirement now or after the implementation of Action 8 for changes to the Inkomstskattelagen, and particular the Korrigeringsregeln. READ MORE

  3. 8. Transfer Pricing in the Context of Strategic Congruence

    University essay from Uppsala universitet/Företagsekonomiska institutionen; Uppsala universitet/Företagsekonomiska institutionen

    Author : My Eliasson; Adam Mankowski; [2017]
    Keywords : Transfer Price; Strategy; Strategic Congruence; Operational Efficiency; Managerial Objectives;

    Abstract : The most common approach towards transfer pricing has been purely economic or with focus on tax regulations. However, transfer pricing has developed to become a component of organizational strategy. This indicates a growing focus on transfer pricing from a managerial perspective. READ MORE

  4. 9. 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

    Author : ANTON SÖDERBERG; ALEXANDER WALLENBERG; [2016]
    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

  5. 10. 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