Essays about: "the arm s length principle"
Showing result 26 - 30 of 36 essays containing the words the arm s length principle.
-
26. Transfer Pricing - the global divergences regarding the documentation requirements
University essay from Göteborgs universitet/Juridiska institutionenAbstract : The globalization, the international trade and the number of multinational enterprises have continued to increase over the last decade and today over 70 percent of the cross-border transactions take place between related enterprises. The growth of multinational enterprises which are doing cross-boarder transactions present increasingly complex taxation issues, both for the tax administrations and the companies themselves. READ MORE
-
27. Practical applicability of methods to determine the transfer price of intangibles
University essay from IHH, RättsvetenskapAbstract : This master’s thesis discusses and analyzes difficulties in transfer pricing methods’ applicability to intangibles. With basis from the OECD Transfer Pricing Guidelines and the U.S. regulations, this thesis investigates applicable methods in legislation, theory, recommendations, case law and how they are applied in practice. READ MORE
-
28. The Concept of Commensurate with Income : Retroactive adjustments and the arm's length standard
University essay from IHH, RättsvetenskapAbstract : This master’s thesis deals with the transfer pricing of intangibles and focuses on the U.S. standard commensurate with income. This standard has been accused of being incompatible with the overriding principle of transfer pricing, the arm’s length standard, and is not endorsed by the OECD. READ MORE
-
29. Transfer Pricing Profit Split Methods : A Practical Solution?
University essay from IHH, RättsvetenskapAbstract : The purpose of this master’s thesis is to explain and analyze whether today’s existing regulations provide sufficient guidance on how to apply the Profit Split Method (PSM) in practice. Since the enterprises’ profits arising from intra-group transactions increases, the tax base for any government also becomes larger and more important. READ MORE
-
30. Customs Valuation and Transfer Pricing : Two Sides of the Same Coin
University essay from IHH, RättsvetenskapAbstract : The purpose of this master’s thesis is to examine and analyse how a transfer pricing adjustment is made and how related parties should handle price adjustments from a customs perspective in Sweden. The examination includes describing the valuation methods available for transfer pricing and customs valuation with regards to related parties. READ MORE
