Essays about: "transfer pricing tax"

Showing result 1 - 5 of 78 essays containing the words transfer pricing tax.

  1. 1. 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 institutionen

    Author : Alexandre Magno Ramos Paiva; [2023]
    Keywords : Arm’s Length Principle; Practicability Principle; Transfer Pricing; Fiscal Sovereignty; Commodities.;

    Abstract : 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

  2. 2. 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 handelsrätt

    Author : Wihan Esterhuizen; [2023]
    Keywords : Tax; EU Law; OECD S Pillar One; principles of law; ability-to-pay; territoriality; state aid; transfer pricing; Arm s length principle; Law and Political Science;

    Abstract : 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

  3. 3. 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 handelsrätt

    Author : Priyanka Kumari Prasad; [2023]
    Keywords : Unilateral measures; Equalisation levy; Diverted Profit Tax; Digital economy; Value creation approach; Juridical double taxation; OECD s Pillar One.; Law and Political Science;

    Abstract : 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

  4. 4. The Grey Area of Taxation - An essay on Low Value-Adding Services in Swedish Tax Law

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Douglas Linton Wahlgren; [2023]
    Keywords : skatterätt; finansrätt; koncerninterna tjänster; internprissättning; vinstallokering; Law and Political Science;

    Abstract : This essay critically examines the legal aspects of low value-adding services within multinational corporations, focusing on their treatment in Swedish tax law and the OECD Transfer Pricing Guidelines (OECD TPG). It explores the challenges and complexities involved in defining and taxing intragroup services, emphasizing their impact on profit shifting strategies. READ MORE

  5. 5. Artem Tuigunov_Tax Regulation of Transfer Prices in Transnational Corporations in EU

    University essay from Lunds universitet/Nationalekonomiska institutionen

    Author : Artem Tuigunov; [2022]
    Keywords : Transfer prices; Tax regulation; EU; BEPS; Multilateral Intrument; Business and Economics;

    Abstract : This work provides an overview of transfer pricing itself, how the tax regulation of transfer pricing has changed in EU and the analysis of changes in revenue and profits of 5 different Transnational corporations from Denmark. The analysis was made by looking into annual reports of these corporations for more than a decade and comparing the result with the time of introduction of BEPS plan and the Multilateral Instrument. READ MORE