Essays about: "thesis on transfer pricing"
Showing result 6 - 10 of 56 essays containing the words thesis on transfer pricing.
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6. Secondary Transfer Pricing Adjustments: Interpretation Challenges within the EU and International Perspectives
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This master thesis elaborates on the issues of the secondary transfer pricing adjustments that are common yet not regulated in an efficient manner by the states. The core problem of the double taxation issues to follow is the unwillingness of the states to accept the administrative tax decisions of each other in such sensitive fields as transfer pricing. READ MORE
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7. 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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8. 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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9. Transfer pricing rules as trade restrictions: Is the OECD’s HTVI approach compatible with the EU fundamental freedoms?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This thesis considers whether the OECD’s HTVI approach is compatible with the EU fundamental freedoms. Its conclusions are of relevance to EU Member States who have implemented, or are looking to implement, the HTVI approach as part of a national transfer pricing regime. READ MORE
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10. 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
