Results 241 to 250 of about 1,019 (271)

Motor-Free Soft Robots for Cancer Detection, Surgery, and In Situ Bioprinting. [PDF]

Adv Healthc Mater
Nguyen CC, Davies J, Ashok A, Hoang TT, Ehteda A, Dang TB, Nicotra E, Tran HA, Sharma B, Zhu K, Phan PT, Ji A, Wan J, Rnjak-Kovacina J, Vittorio O, Phan HP, Lovell NH, Do TN.   +17 more
europepmc   +1 more source

Why the Arm’s Length Principle Should Be Maintained

International Transfer Pricing Journal, 2020
The OECD’s so-called “Pillar One Proposal” partly overrules the arm’s length principle. The authors argue that this is a step in the wrong direction. Instead, the arm’s length principle should be further developed by reducing complexity and ensuring legal certainty.
U. Schreiber, D.(Dirk) Simons, S. Greil, M. Lagarden   +3 more
core   +4 more sources

Transfer Pricing and the Arm's Length Principle After BEPS

, 2017
Abstract This book examines the transfer pricing rules, including the arm's length principle (ALP), in the context of the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. It considers the nature and scope of the transfer pricing rule starting with an explanation of how and on what basis the rules were created.
Richard Collier, Joseph L Andrus
openaire   +2 more sources

Transfer pricing and the Arm's length principle [PDF]

, 2008
The Diploma Thesis is devoted to the Transfer pricing problematic, whereby the Transfer Pricing and the Arm's length principle as such are defined, further the Czech and Slovak transfer pricing law is presented and the different transfer pricing together with their possible usage are described.
Hájková, Hana
openaire   +2 more sources

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Competencies, Competence and the Arm’s Length Principle

Bulletin for International Taxation, 2023
This article is concerned with competencies and competency assets, a form of intangible asset. The discussion deals primarily with the nature of competency assets, and why they are important in the context of the current income allocation rules, despite being barely recognized by the OECD Transfer Pricing Guidelines.
R.S. Collier, I.F. Dykes
openaire   +1 more source

The COVID-19 Pandemic and the Arm's Length Principle

6th FEB International Scientific Conference 2022, 2022
The wide-ranging economic impacts of the COVID19 pandemic suggest that previous analysis methods such as the arm’s length principle can no longer be fully applied in the usual way. The SARS-CoV-2 virus has disrupted companies’ accounting, administration, and controlling systems.
Rita Tóth, Tamás Kovács
openaire   +1 more source

Practical Application of the Arm’s Length Principle

2017
Abstract This chapter provides a general summary of transfer pricing practices prior to the Base Erosion and Profit Shifting (BEPS) Project. The summary is based primarily on the principles and concepts contained in the 2010 version of the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines and in ...
Richard S Collier, Joseph L Andrus
openaire   +1 more source

Stock-Based Compensation and the Arm’s Length Principle

International Transfer Pricing Journal, 2018
This article will explain the background and the accounting/tax implications of stock-based compensation (SBC) and its context within transfer pricing (TP) and the arm’s length principle. More specifically, the article will focus on the inclusion of SBC in the cost base for TP purposes.
S. Hubscher, J.(Jacky) Houlie
openaire   +1 more source

Multinational Transfer Pricing, Tax Arbitrage, and the Arm's Length Principle

SSRN Electronic Journal, 2004
This paper studies the multinational firm's choice of transfer prices when the firm uses separate transfer prices for tax and managerial incentive purposes, and when there is penalty for non‐compliance with the arm's length principle. The optimal incentive transfer price is shown to be a weighted average of marginal cost and the optimal tax transfer ...
CHONGWOO CHOE, CHARLES E. HYDE
openaire   +1 more source

Applying the Arm’s Length Principle to Group Synergies

International Transfer Pricing Journal, 2020
This article deals with the basic antagonism between group synergies and the arm’s length principle. On the one side, group synergies arise from the interactions between members of a group. On the other side, the arm’s length principle is based on the fiction that members of a group operate separately, as if they were unrelated.
openaire   +1 more source