Results 21 to 30 of about 14,190 (298)
Judicial Review of Labor Agreements: Lessons From the Sports Industry [PDF]
Recently, climate engineering and particularly sulphur aerosol injection (SAI) have entered the arena of international climate change politics. The idea behind SAI is very simple: to reflect sunlight and heat back into space by injecting particles into ...
Weistart, John C.
core +4 more sources
The e-commerce platforms have facilitated the information flow of cross-border supply chain (CBSC) and attracted a wide range of companies and individuals to participate in cross-border businesses.
Dong Mu, Huanyu Ren, Chao Wang
doaj +1 more source
Arm's Length Principle in Intangible Assets Valuation [PDF]
All transactions in multinational enterprises which are realized among group members are very sensitive to tax risks arising from (appropriate) asset valuation. The more often the transactions are connected to intangible assets or R&D services the more tax risks they generate.
openaire +1 more source
Related party transactions and audit risk
Related Party Transactions (RPTs) are perceived as genuine transactions, which fulfill the economic needs of a company. However, the controlling shareholders may use RPTs as a tool for transferring the firm’s resources for their private benefit. The dual
Abdul Rasheed P. C +2 more
doaj +1 more source
Transfer Pricing and Enforcement Policy in Oligopolistic Markets [PDF]
We set up a symmetric two-country model with two multinationals competing on the quantities and possibly manipulating their transfer prices. Governments choose both the corporate profit tax rate and the level of enforcement of the "arm's length ...
Amerighi, Oscar
core +2 more sources
Revised OECD Transfer pricing Guidelines and the Czech tax policy
In applying the international principles to the taxation of Multinational Enterprises, one of the most difficult issues that have arisen is the establishment for tax purposes of appropriate transfer prices.
Veronika Solilová
doaj +1 more source
The arm's length principle and distortions to multinational firm organization [PDF]
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the arm's length principle in corporate taxation and use comparable market prices to ‘correctly’ assess the value of intracompany trade and royalty income of multinationals.
Keuschnigg, Christian +1 more
openaire +3 more sources
This paper aims to the analysis of the most common methods of controlled transactions, and the interpretation of the arm’s length principle under the view of the tax income comparison between countries with high and low tax rates.
Challoumis Constantinos
doaj +1 more source
Fairness and the Arm's Length Principle in a Digital Economy [PDF]
Die OECD Base Erosion Profit Shifting (BEPS) Initiative sowie die aktuelle Fairness orientierte öffentliche Diskussion zur Besteuerung digitaler Geschäftsmodelle verdeutlichen die Bedeutung und Komplexität des Fremdvergleichsgrundsatzes. Wir modellieren einen international fragmentierten Produktionsprozess eines digitalen Gutes und zeigen wie Fairness ...
Greil, Stefan +2 more
openaire +3 more sources
Thin Capitalisation Safe Harbour Rules: A Proposed Conceptual Legislative Design
Current legislation in respect of thin capitalisation is viewed as unclear and complex, which has resulted in both the Davis Tax Committee and National Treasury commenting that thin capitalisation safe harbour rules should be investigated for ...
Lize Goosen, Cecileen Greeff
doaj +1 more source

