Essays about: "Transfer Pricing"

Showing result 6 - 10 of 80 essays containing the words Transfer Pricing.

  1. 6. 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

  2. 7. 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 : Intangibles; Transfer Pricing; 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

  3. 8. Definition and valuation of intangible assets for international transfer pricing purposes

    University essay from Lunds universitet/Juridiska institutionen

    Author : Irina Timoshenko; [2015]
    Keywords : intangible assets; transfer pricing; Business and Economics;

    Abstract : .... READ MORE

  4. 9. Collateral choice option valuation

    University essay from KTH/Matematisk statistik

    Author : Sébastian Mollaret; [2015]
    Keywords : Collateral; optimal collateral posting; multi-currency collateral; collateral pricing; collateral discounting; conditional independence.;

    Abstract : A bank borrowing some money has to give some securities to the lender, which is called collateral. Different kinds of collateral can be posted, like cash in different currencies or a stock portfolio depending on the terms of the contract, which is called a Credit Support Annex (CSA). READ MORE

  5. 10. How do Unilateral APAs overcome the issues of legitimate expectations, tax transparency and state aid in the European Union?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Jessica Cuanita; [2015]
    Keywords : advance pricing agreements; principle of legality; legitimate expectations; tax transparency; unilateral APA; state aid; advance pricing arrangements; transfer pricing; Law and Political Science;

    Abstract : Advance pricing arrangement (“APA”) becomes a common tool to attract foreign investors to carry out their business in the Member States’ territory. The advantage of APA which providing legitimate expectations to the taxpayers is one of the reasons of why the companies file an APA request to the tax authorities. READ MORE