Results 11 to 20 of about 2,984,464 (228)

Beyond the Arm's Length Principle

, 2021
The arm's length principle and the notion of permanent establishment are the two pillars of international corporate tax. Drafted in 1920, they are now under the fire of acute criticism and they appear to have become obsolete: they are unable to face the ...
Ballivet, Louis
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Profit shifting under the arm's length principle [PDF]

, 2023
This study analyses the tax-induced profit shifting behaviour of firms and the impact of governments' anti-shifting rules. We derive a model of a firm that combines internal sales and internal debt in a full profit shifting strategy, and which is ...
Rathke, Alex A. T.
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The Brazilian Adoption of the Arm's Length Principle : Considerations and its Impact on the Country's Fiscal Sovereignty in Cross-border Commodities Transactions

, 2023
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.
Paiva, Alexandre Magno Ramos
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Transfer pricing and the arm's length principle after BEPS /

, 2023
In this detailed and up-to-date publication on the laws of transfer pricing, the authors analyse the impact of the Base Erosion and Profit Shifting (BEPS) project and consider the future for the 'arm's length principle' as a basis for future transfer ...
Collier, Richard S.,, Andrus, Joseph L.,
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ASSESSMENT OF THE PRE-CONDITIONS FOR THE IMPLEMENTATION OF MODERN TECHNOLOGIES OF TAX CONTROL ON BASE EROSION AND PROFIT SHIFTING

Соціальна економіка, 2022
The purpose of the study is to assess the possibility of combining the concepts of transfer pricing, beneficial owner of income and valid business purpose in a model of three-component tax risk assessment for countering BEPS. To achieve this purpose, the
Dmytro Nosenko
doaj   +1 more source

The Arm's Length Principle and Tacit Collusion [PDF]

, 2011
The arm's length principle states that the transfer price between two associated enterprises should be the price that would be paid for similar goods in similar circumstances by unrelated parties dealing at arm's length with each other.
Choe, Chongwoo, Matsushima, Noriaki
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Transfer Pricing Methods for Services and the Policy of Fixed Length Principle

Economics and Business, 2019
The paper deals with the methods used by companies for controlled transactions in services. The author performs an analysis of the ways a company that takes part in controlled transactions of transfer pricing can tackle tax issues using an adequate tax ...
Challoumis Constantinos
doaj   +1 more source

Transfer pricing and safe harbours

Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis, 2013
Transfer prices are significant for both taxpayers and tax administrations because they determine in large part taxable profits of associated enterprises in different tax jurisdictions.
Veronika Solilová
doaj   +1 more source

Media policy in Greenland

Nordicom Review, 2021
This article describes the historical development of media policy in Greenland, and the shifts in the underlying normative and causal ideas that legitimise media policy.
Ravn-Højgaard Signe
doaj   +1 more source

ARM'S LENGTH AND FREE COMPETITION INTERVAL

, 2023
reservedVisto i continui adattamenti delle normative nazionali sul tema dei prezzi di trasferimento alle linee guida del Modello di convenzione OCSE contro le doppie imposizioni, si vogliono illustrare gli aggiornamenti effettuati alla base dei principi ...
HU, YONG DAN
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