Essays about: "transfer pricing documentation"
Showing result 1 - 5 of 17 essays containing the words transfer pricing documentation.
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1. Tax Penalties in Transfer Pricing
University essay from Uppsala universitet/Juridiska institutionenAbstract : The purpose of this thesis is to examine both the conditions for levying tax penalties in transfer pricing and the sustainability of the Swedish tax penalty framework in regard to transfer pricing in a post-BEPS world. This question is of relevance as BEPS has resulted in more extensive documentation requirements, affecting both the tax payer’s tax assessment procedure and the Swedish Tax Agency’s auditing practice. READ MORE
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2. 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 finansieringAbstract : 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
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3. BEPS Action plan 13 in the light of confidentiality
University essay from Lunds universitet/Institutionen för handelsrättAbstract : OECD introduced 15 Action plans as part of the BEPS-project in 2014 in their work to combat base erosion and profit shifting (BEPS). Action plan 13 provides for a re-examined transfer pricing documentation and a new Country-by-country-reporting. The CbC-reporting is to be included in a three-tired approach including a master-file and a local-file. READ MORE
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4. BEPS Action 13: Standardized Transfer Pricing Documentation - Does one size fit all?
University essay from Lunds universitet/Juridiska institutionenAbstract : In Action 13 of the OECD/G20 Base erosion and profit shifting project, the Organization for Economic Co-operation and Development (OECD) re-examines transfer pricing documentation requirements and updates Chapter V of the Transfer pricing guidelines. Action 13 recommends a new three-tiered transfer pricing documentation structure that includes a master file, a local file, and a country-by-country report. READ MORE
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5. Transfer Pricing Documentation : - In Need Of A Harmonization?
University essay from Högskolan i Jönköping/IHH, RättsvetenskapAbstract : In today's global world where internal cross-border transactions are made in a vast amount and thereby affect the economy to a large extent the area of transfer pricing has become more important than ever. Therefore the organization for economic co-operation and de-velopment (OECD) have started the base erosion and profit shifting project which aims to prevent the exploiting of gaps and differences of regulations in different states in cross-border transactions. READ MORE
