Essays about: "transfer pricing comparability analysis"

Found 4 essays containing the words transfer pricing comparability analysis.

  1. 1. Business Restructuring : The applicability of the arm's length principle for intangibles with an uncertain value at the time of the restructuring

    University essay from IHH, Rättsvetenskap

    Author : Ida Claesson; [2012]
    Keywords : Transfer Pricing; Business Restructurings; The Arm s Length Principle; Intangibles; Uncertain value;

    Abstract : This thesis is based on the regulations found in the OECD model and the OECD TP guidelines concerning the arm’s length principle. The core of the arm’s length principle is that transactions between associated enterprises should be treated the same as transactions between independent enterprises. READ MORE

  2. 2. Documentation within Transfer Pricing : A case study

    University essay from IHH, Företagsekonomi

    Author : Johan Lagerqvist; Yan Cheng; [2009]
    Keywords : Transfer pricing; documentation requirements; arm s length principle; OECD; tax authority;

    Abstract : Purpose: The overall purpose of this thesis is to provide an analysis of the effects of the documentation requirements on transfer pricing and provide a clearer picture of the documentation requirements in transfer pricing. Furthermore, the purpose is to analyze whether the chosen method of Superfos is adequate related to the new regulations. READ MORE

  3. 3. Developing a transfer pricing system : A case study of a company in the marine foodservice industry

    University essay from IHH, Rättsvetenskap

    Author : Elin Andersson; [2009]
    Keywords : Transfer Pricing System; Galley; Comparison; Enterprise; Transaction;

    Abstract : Marine Food group is active within the marine foodservice industry and is established in Finland, Sweden, USA and Singapore. The group both sells galley equipment and spare parts as well as carrying out installation of the marine foodservice areas in both new build vessels and in vessels where an old galley is changed into a new one. READ MORE

  4. 4. Attribution of Profits to Permanent Establishments : How Should Swedish Legislation Conform to the OECD December 2006 Report?

    University essay from IHH, Rättsvetenskap

    Author : Maria Blom; Anders Lenfors; [2008]
    Keywords : International Tax Law;

    Abstract : The purpose of this thesis is to establish whether the domestic legislation of Sweden is in tune with the OECD December 2006 report on the attribution of profits to permanent es-tablishments (December 2006 report) and if not how Sweden ought to conform. How to attribute business profits to a permanent establishment (PE) is laid down in Article 7 of the OECD Model Tax Convention on Income and on Capital. READ MORE