Essays about: "thesis on transfer pricing"
Showing result 1 - 5 of 56 essays containing the words thesis on transfer pricing.
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1. Open Innovation or Anti-Competitive Abuse? A Case-Study on the Tesla Patent Pledge under European Union Competition Law
University essay from Göteborgs universitet/Juridiska institutionenAbstract : Patent Pledges can be defined as “voluntary commitments by patent holders to limit enforcement of their patents, made to the public or large segments of specific markets”. In terms of IP strategy, it is a relatively new strategy, only having a history of 20 or so years. READ MORE
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2. The Brazilian Adoption of the Arm's Length Principle : Considerations and its Impact on the Country's Fiscal Sovereignty in Cross-border Commodities Transactions
University essay from Uppsala universitet/Juridiska institutionenAbstract : The thesis critically examines the Brazilian adoption of arm's length principle and assesses its impact on the country's fiscal sovereignty in cross-border commodities transactions. The arm's length principle is regarded as an useful tool for preventing tax avoidance and ensuring tax neutrality. READ MORE
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3. The digital economy and its implications: does the OECD’s Pillar One Proposal challenge the principles of law within International and EU tax law?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Change is the only constant; yet, as we step into the brave new world of taxing the digital economy, it might seem like the need and development of principles and rules for adequate profit allocation has only begun. This thesis discusses the profit allocation rules under the Unified Approach of the OECD Pillar One Proposal Amount A in relation to three identified principles of law in international and European tax law. READ MORE
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4. Problems caused by unilateral measures while taxing the digital economy: Does the value creation approach suggested by OECD solve the problem?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This thesis examines the challenges arising from unilateral measures taken by both developing and developed countries to protect their taxing rights in the digital economy, leading to issues of double taxation. It focuses on India's equalisation levy and the UK's diverted profits tax (DPT) as examples of unilateral measures. READ MORE
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5. 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
