Essays about: "thesis on transfer pricing"

Showing result 6 - 10 of 47 essays containing the words thesis on transfer pricing.

  1. 6. Turned Tables in The Global Economy : Chinese Outward Foreign Direct Investment and Cultural Risk Reduction in Sweden

    University essay from Södertörns högskola/Företagsekonomi; Södertörns högskola/Företagsekonomi

    Author : Carl-David Lundström; Ingrid Höllisch; [2017]
    Keywords : Outward foreign direct investment; FDI; internationalization; Uppsala model; network approach; born-global; bred-global; establishment; risk; risk reduction; Sweden; China; guanxi; guanxiwang; Hofstede; trade-facilitating organizations; investment-facilitating organizations; psychic distance; cultural distance;

    Abstract : Background: People’s Republic of China has attracted much FDI throughout the decades. According to the World Bank (2016), China has received approximately 20 per cent of the total FDI to developing countries the last ten years which has contributed to the country’s huge economic growth. READ MORE

  2. 7. Hard to value intangibles from a Swedish perspective

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Håkan Vahlsten; [2017]
    Keywords : BEPS Action 8-10; Transfer Pricing; Arm s length principle; Arm s length distance; Inkomstskattelagen; Korrigeringsregeln; Intangibles; Hard To Value Intangibles; HTVI; Law and Political Science;

    Abstract : 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

  3. 8. Impact and Adoption of Flexibility in a Rigid and Centralized Distribution Network : A Case Study on a Global Manufacturing Company

    University essay from KTH/Industriell Management; KTH/Industriell Management

    Author : ANTON SÖDERBERG; ALEXANDER WALLENBERG; [2016]
    Keywords : Manufacturing and Distribution Network; Standardization; Centralization;

    Abstract : For manufacturing firms to succeed in the global marketplace it is important that they have an efficient supply chain that is well adapted to the characteristics of the products.This thesis explore the companies' challenge to adapt its supply chain to the characteristics of  heir products. READ MORE

  4. 9. How can the proposed changes to the OECD tax model convention in action 1 and action 7 counter the issue of an artificial avoidance of a PE status?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Maria Wettersten; [2016]
    Keywords : Permanent establishment; BEPS action 1; BEPS action 7; artificial avoidance; Law and Political Science;

    Abstract : The purpose of this thesis is to clarify how, according to BEPS action 1 and action 7, can the amendments of the “specific activity exemptions” in article 5 paragraph 4 of the OECD Model Tax Convention on Income and Capital (the model convention) counter the issue of an artificial avoidance of a PE status. The main issues that are connected to the concept of a permanent establishment are artificial avoidance of the status of a permanent establishment, the use of transfer pricing rules in order to artificially allocate the profits of a permanent establishment to low tax states and finally that some enterprises that operate within the digital economy can avoid the status of a permanent establishment due to the lack of physical presence. READ MORE

  5. 10. Transfer Pricing Treatment of Transactions with Hard-to-Value Intangibles: Is BEPS Action 8 Based on the Arm’s Length Principle?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Oleh Fedusiv; [2016]
    Keywords : Transfer Pricing; Intangibles; Hard-to-Value Intangibles; BEPS; Arm’s Length Principle; Law and Political Science;

    Abstract : This master’s thesis analyses BEPS Action 8 recommendations in relation to transactions with hard-to-value intangibles. OECD has developed them with a view to ensure that transfer pricing outcomes of transactions with hard-to-value intangibles are aligned with value creation. READ MORE