Essays about: "internprissättning"
Showing result 1 - 5 of 23 essays containing the word internprissättning.
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1. Is control over risk getting out of control? : An analysis of the concept of control over risk as set out in the 2022 OECD Guidelines in relation to Swedish law
University essay from Uppsala universitet/Juridiska institutionenAbstract : In 2017 an amended version of the OECD Transfer Pricing Guidelines was published which included new provisions to prevent BEPS through the shifting of risks. Through the amendment of the Guidelines, it was clarified that for an entity in an MNE to contractually assume a risk, for transfer pricing purposes, it needs to control the risk and have the financial capacity to assume it. READ MORE
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2. The Grey Area of Taxation - An essay on Low Value-Adding Services in Swedish Tax Law
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : This essay critically examines the legal aspects of low value-adding services within multinational corporations, focusing on their treatment in Swedish tax law and the OECD Transfer Pricing Guidelines (OECD TPG). It explores the challenges and complexities involved in defining and taxing intragroup services, emphasizing their impact on profit shifting strategies. READ MORE
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3. The notion of economic value in taxation - A comparison of valuation methods
University essay from Lunds universitet/Juridiska fakulteten; Lunds universitet/Juridiska institutionenAbstract : The concept of economic value is not well explored nor consistently applied in the field of taxation. Different systems of taxation assess value from their own perspectives and with their own interests in mind resulting in situations where different values for taxation are determined for the same transaction. READ MORE
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4. The Seeking of a Business-Optimal Transfer Price - In accordance with the Arm's Length Principle
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : The search of a business-optimal transfer price has been going on for decades. One interesting solution aimed to, by the use of game theory, bargaining theory and transfer pricing, create a quantitative solution to optimize the global profits of a multinational enterprise. READ MORE
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5. 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
