Essays about: "transfer pricing intangibles"
Showing result 11 - 15 of 16 essays containing the words transfer pricing intangibles.
-
11. Business Restructurings : Transfer Pricing Aspects from a Distributor's Perspective - When Should Shifted Profit Potential be Remunerated?
University essay from Högskolan i Jönköping; IHH, RättsvetenskapAbstract : The OECD Guidelines stipulates that a business restructuring resulting in shifted profit potential not automatically implies that compensation should be paid between the restructuring parties. This thesis examines when shifted profit potential should be remunerated from the perspective of the fictive Swedish distributor Enterprise A which is facing a business restructuring. READ MORE
-
12. Intangible Property : Defining Intangible Property for Transfer Pricing Purposes and Exploring the Concept of Economic Ownership
University essay from Internationella HandelshögskolanAbstract : In this thesis the definition of intangible property contained in the Transfer Pricing Guidelines is analysed with the aim of exploring whether it is satisfactory or not. Furthermore, the need to have a definition of intangible property for transfer pricing purposes at all is explored. READ MORE
-
13. 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
-
14. 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
-
15. 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
