Essays about: "Transfer pricing"

Showing result 1 - 5 of 84 essays containing the words Transfer pricing.

  1. 1. Is the Commission’s Arm’s Length Principle Compatible with the Principle of Legal Certainty?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Rachel Ashon; [2017]
    Keywords : Arm s Length Principle; European Union; Transfer Pricing; Advanced Pricing Arrangements; Tax Law; Law and Political Science;

    Abstract : The European Commission’s Decisions addressing tax rulings which came into the public domain in November 2014 as constituting State Aid (contrary to Article 107 TFUE) after Lux-Leaks have generated some discussion. Of paramount interest in this thesis is the Commission’s declaration in the Belgium Excess Profits, Fiat and Starbucks Decisions that the European Union has its own ALP (hereinafter called EC-ALP). READ MORE

  2. 2. The EU State Aid Prohibition and Taxation – The Expanding Scope of Art. 107 TFEU

    University essay from Lunds universitet/Juridiska institutionen

    Author : Åke Häggqvist; [2017]
    Keywords : EU-Rätt; EU-Law; statligt stöd; state aid; skatterätt; tax law; transfer pricing; tax competition; aggressive tax planning; Law and Political Science;

    Abstract : A topic that has received a significant amount of attention within the international community is the concept of harmful tax competition. This is of particular relevance to the EU due to the additional exposure to this problem the Member States experience by virtue of the internal market. READ MORE

  3. 3. 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

  4. 4. 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

  5. 5. Transfer Pricing’s Effects on Accountability: A conflict of accountability demands

    University essay from Göteborgs universitet/Graduate School

    Author : Lisa Berggren; Anneli Helenius; [2016-09-15]
    Keywords : Transfer pricing; accountability; conflict of accountability demands; management control;

    Abstract : MSc in Accounting.... READ MORE