Essays about: "the OECD Transfer Pricing Guidelines"
Showing result 1 - 5 of 32 essays containing the words the OECD Transfer Pricing Guidelines.
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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. Link between Transfer Pricing and Customs Union Regulations
University essay from Uppsala universitet/Juridiska institutionenAbstract : Base erosion and profit sharing (BEPS) explain the process when multinational enterprises take advantage of the gaps, mismatches or loopholes in the international tax regulations for artificially shifting profits to lower tax jurisdictions or no tax jurisdictions. Tax avoidance strategies were legal in most cases and overlooked until the OECD G20 BEPS project was done in 2013. READ MORE
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4. 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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5. Can the Arm’s Length Principle in the OECD Transfer Pricing Guidelines Fulfil the Minimum Requirements of the Transaction Approach in the Controlled Foreign Company Rules under Anti-Tax Avoidance Directive?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Generally, the ALP in TP regulations is widely applied in order to prevent price manipulation which will cause tax avoidance. And CFC regulations have usually been regarded as a “backstop” of TP regulations in terms of combating tax avoidance. READ MORE
