Essays about: "Transfer Pricing System"

Showing result 1 - 5 of 21 essays containing the words Transfer Pricing System.

  1. 1. Eu State Aid Rules And Corporate Direct Tax Arrangements : An Analysis of Article 107(1) TFEU and Recent case Developments with the principle of Legality

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Sharon Mame Sika Värttö; [2022]
    Keywords : State aid; Tax ruling; Tax avoidance; Hybrid arrangement; Aid recovery; Legality; Legal certainty; Selective advantage; Harmful tax competition; Transfer pricing; Arm’s length principle; Economic advantage.;

    Abstract : The European Union was devised to promote competition in the international market environment and ensure balanced allocation of fiscal and political requirements of the Member States. Globalization has led to enabling tax environments through granting of tax benefits by EU Member jurisdictions intended to promote competition in attracting foreign investment, trade, and development. READ MORE

  2. 2. Valuation of Transactions Related to Intangibles from Transfer Pricing and VAT Perspective

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Davit Berdzuli; [2020]
    Keywords : Law and Political Science;

    Abstract : What are the intangibles and how transactions related to them should be evaluated from a direct and indirect tax perspective is one of the crucial questions of the modern tax systems and business operators. OECD provides a combination of methods and rules that can be applied for direct tax purposes. READ MORE

  3. 3. Tax Penalties in Transfer Pricing

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Carl-Johan Lindman; [2019]
    Keywords : tax penalties; transfer pricing; Skattetillägg; Internprissättning;

    Abstract : 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

  4. 4. 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 : Background and problem: Divisionalized firms often use transfer pricing as a means of controlling and evaluating separate units. Since transfer pricing creates an economic relationship between units and accounting information of the unit’s performance, transfer pricing is argued to have an effect on accountability. READ MORE

  5. 5. 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