Essays about: "advance pricing agreements"
Found 5 essays containing the words advance pricing agreements.
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1. Transfer pricing adjustments derived from state aid cases - Are corresponding adjustments mandatory for EU Member States?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : When an EU MS executes a state aid recovery decision, specifically those cases regarding Advance Pricing Agreements (APAs), an economic double taxation issue and a potential TP dispute may arise, which could be generated by the need for the application of a corresponding adjustment. In any case, each jurisdiction has the discretion to determine if the application of a corresponding adjustment should be made. READ MORE
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2. The Commission’s Approach in State Aid Assessment of Advance Pricing Agreements: an Autonomous EU Arm’s Length Principle and Its Implications
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : This thesis aims to reveal whether the Commission’s approach in the State aid assessment of advance pricing agreements (APAs) is in line with the current EU law framework and whether, given its implications, it is a sensible development in State aid law applied to taxation. Chapter 2 introduces the background of the arm's length principle, looking into its origin, purpose and application in tax law. READ MORE
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3. 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 handelsrättAbstract : 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
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4. Transfer Pricing Disputes in Kenya: Advance Pricing Agreements the Way Forward?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Kenya, like the rest of the world, in an effort to protect its tax base, has enacted a transfer pricing (TP) legislation requiring, among other things, that inter-company transactions be conducted at arm’s length. However, due to the very nature of TP transactions, the determination of the correct arm’s length price or profit margin has remained a major challenge, not only for the taxpayers, but for the tax authority as well. READ MORE
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5. Advance pricing agreements : The concept and its implementation in Swedish tax law
University essay from IHH, FöretagsekonomiAbstract : Transfer pricing (TP) has for a long time been an important tax issue, however it is only within the past decade that it has gotten the attention it deserves. This since more and more corporations becomes globalized. When setting a TP within a multinational enterprise (MNE) it is important to consider the arm’s length principle. READ MORE
