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(Series Information) European Papers - A Journal on Law and Integration, 2016 1(3), 1259-1261 | European Forum Highlight of 20 September 2016 | (Abstract) In its decision of 30 August 2016, the European Commission found that Ireland granted undue tax ...
Giulia D'Agnone
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Transfer pricing tools for adjusting the company’s profitability
The article examines the tools for adjusting the company’s profitability, which can be used in transfer pricing. In recent decades, countries have adopted various rules to combat tax evasion and tax avoidance.
D.M. , O.S.
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Transfer Pricing and the Arm's Length Principle Under Imperfect Competition [PDF]
This paper analyzes incentives of a multinational enterprise to manipulate an internal transfer price to take advantage of corporate-tax differences across countries under both monopoly and oligopoly. We examine “cost plus” and “comparable uncontrollable price” as two alternative implementations of the so-called arm’s length principle (ALP) to mitigate
CHOI, Jay Pil +2 more
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Directorate General of Taxes amends its supervision business process to require Account Representatives to conduct transfer pricing analysis. As an international standard, transfer pricing must adhere to the arm's length principle.
Heni Wuryaningsih, Siti Nuryanah
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Aldehyde dehydrogenase 1A1 (ALDH1A1) is a cancer stem cell marker in several malignancies. We established a novel epithelial cell line from rectal adenocarcinoma with unique overexpression of this enzyme. Genetic attenuation of ALDH1A1 led to increased invasive capacity and metastatic potential, the inhibition of proliferation activity, and ultimately ...
Martina Poturnajova +25 more
wiley +1 more source
Modern manufacturing entities often operate in capital groups, and their role is sometimes limited to the function of cost centers. From the legal point of view, however, they are separate entities obliged to apply transfer pricing regulations.
Sulik-Górecka Aleksandra
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Pharmacological inhibition of PERK in a DEN‐induced mouse model of liver cancer does not reduce tumor burden but alters cellular stress signaling. Despite blocking PERK activity, downstream stress responses, including CHOP expression, remain active, suggesting compensatory mechanisms within the unfolded protein response that may influence tumor ...
Ada Lerma‐Clavero +5 more
wiley +1 more source
ABSTRACT Background Accessing brain magnetic resonance imaging (MRI) can be challenging, especially for underserved patients, which may lead to disparities in neurological diagnosis. Method This mixed‐methods study enrolled adults with one of four neurological disorders: mild cognitive impairment or dementia of the Alzheimer type, multiple sclerosis ...
Maya L. Mastick +19 more
wiley +1 more source
In Principle, (Im)possible: Harmonizing an EU Arm’s Length Principle
The arm’s length principle should maintain a tax-level playing field between multinational groups of taxpayers and standalone enterprises. Despite the fact that all EU Member States implemented an arm’s length principle in their domestic transfer pricing rules, differences in the application of the arm’s length principle remain.
openaire +2 more sources
The governance of public bodies in times of austerity [PDF]
Private sector governance arrangements have been imported into UK public bodies under the influence of New Public Management reforms. This paper draws on a cohort study of 14 public bodies to assess the appropriateness of this practice and the impact of ...
Heald, David, Steel, David
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