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Should Wal-Mart, Real Estate Brokers, and Banks Be in Bed Together? A Principles-Based Approach to the Issues of the Separation of Banking and Commerce [PDF]
Lawrence J. White
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Competencies, Competence and the Arm’s Length Principle
Bulletin for International Taxation, 2023This 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
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Why the Arm’s Length Principle Should Be Maintained
International Transfer Pricing Journal, 2020The 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 +3 more
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The COVID-19 Pandemic and the Arm's Length Principle
6th FEB International Scientific Conference 2022, 2022The 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
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Stock-Based Compensation and the Arm’s Length Principle
International Transfer Pricing Journal, 2018This 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
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Practical Application of the Arm’s Length Principle
2017Abstract 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
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Applying the Arm’s Length Principle to Group Synergies
International Transfer Pricing Journal, 2020This 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.
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Multinational Transfer Pricing, Tax Arbitrage, and the Arm's Length Principle
SSRN Electronic Journal, 2004This 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
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International Transfer Pricing Journal, 2020
Traditionally, the arm’s length principle relies on three pillars: the separate entity principle, the relevance of contractual arrangements and the comparability of the transaction. The purpose of this article is to show that, with the BEPS program and Pillars One and Two, new pillars have emerged in the form of allocation keys and safe harbours.
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Traditionally, the arm’s length principle relies on three pillars: the separate entity principle, the relevance of contractual arrangements and the comparability of the transaction. The purpose of this article is to show that, with the BEPS program and Pillars One and Two, new pillars have emerged in the form of allocation keys and safe harbours.
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Transfer pricing issues - the arm's length principle
Development Through Research and Innovation IDSC-2025As the globalization process and international trade has taken off, the number of multinational groups significantly increased. Especially for the past century. In this regard, it is important to address the consequences for the MNEs as well as for national tax authorities.
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