Essays about: "Transfer Pricing intangibles"
Showing result 1 - 5 of 16 essays containing the words Transfer Pricing intangibles.
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1. The incompatible Definitions of Intangibles between the OECD Guidelines and the U.S. Tax Cuts and Jobs Act from a Transfer Pricing Perspective.
University essay from Lunds universitet/Institutionen för handelsrättAbstract : “What discrepancies arise from the incompatible definitions of intangibles for transfer pricing purposes according to the OECD Transfer Pricing Guidelines 2017 and the U.S. READ MORE
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2. Valuation of Transactions Related to Intangibles from Transfer Pricing and VAT Perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
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3. Transfer Pricing of Intangiblesfor Cross-Border Transactions of Associate Companies The : Comparative Study for Intercompany Transfer of Automobile’s Part
University essay from Uppsala universitet/Juridiska institutionenAbstract : Nowadays, there is a lot of creativity in the intellectual property according to the rapid development of technology. Some group companies which has created their intellectual properties usually have the transferred of right between each associated company for the use of intangibles which reflect that the price in such transfer also need to be taken into consideration that it has to be charged in arm’s length, not for free of charge. READ MORE
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4. The Allocation of Residual Profits Deriving from Intangibles in a Transfer Pricing Context
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
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5. Hard to value intangibles from a Swedish perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : 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
