Results 71 to 80 of about 1,019 (271)

The non-neutrality of the arm's length principle with imperfect competition [PDF]

, 2011
The Arm’s Length Principle (ALP) has been broadly adopted by OECD countries to avoid the use of firm’s internal transfer pricing as a device for shifting profits into low tax jurisdictions. While the ALP does not affect market outcomes under perfect competition, we show that its adoption is non-neutral under imperfect competition: a strict (lax ...
Moreno, Diego, Lemus, A.
openaire   +2 more sources

The Impact of ICT on Profit Allocation within Multinational Groups: Arm's Length Pricing or Formula Apportionment? [PDF]

The use of information and communication technologies (ICT) within multinational groups leads to a rising number of intragroup cross-border transactions.
Spengel, Christoph, Schäfer, Anne
core  

Phase Engineering of Nanomaterials (PEN): Evolution, Current Challenges, and Future Opportunities

Advanced Materials, EarlyView.
This review summarizes the synthesis, phase transition, advanced characterization spanning ex situ to in situ and operando techniques, and diverse applications of phase engineering of nanomaterials (PEN). It further outlines key challenges and future opportunities, such as phase stability, architecture control, and artificial intelligence (AI)‐driven ...
Ye Chen, Zhanxi Fan, Jingjie Ge, Qiyuan He, Zhuangchai Lai, Jiawei Liu, Chaoliang Tan, Hua Zhang   +7 more
wiley   +1 more source

The Impact of Transfer Pricing on the Company’s Image. Implications in Audit Work [PDF]

Audit Financiar
In an economy strongly marked by globalisation, transfer pricing is at the top of the agenda of taxpayers, tax authorities and regulatory bodies, with its influence manifested primarily in the fiscal area, respectively in the correct determination and ...
Mihai LUPU, Magda GHICA, Cornelia NASTASE   +2 more
doaj   +1 more source

Advances in Magnesium‐Based Thermoelectrics: A Critical Review

Advanced Materials, EarlyView.
Magnesium‐based thermoelectric materials have emerged as promising candidates for low‐to‐mid‐temperature energy conversion due to their abundance, low cost, and competitive performance. This review summarizes recent advances in Mg3X2, MgAgSb, and Mg2X systems, covering transport mechanisms, fabrication strategies, stability challenges, and device ...
Li‐Min Zhang, Li Zhang, Nan‐Hai Li, Yan‐Ling Yang, Xiao‐Lei Shi, Zhi‐Gang Chen   +5 more
wiley   +1 more source

Weaving Intelligence: Thermally Drawn Multimaterial Fibers Toward AI‐Enabled Smart Textiles

Advanced Materials, EarlyView.
Thermally drawn multimaterial fibers are rapidly advancing as intelligent structural units for next‐generation smart textiles. Integrating multimaterial architectures with neuromorphic and spiking‐neural‐network principles enables fabrics that can sense, compute, and adapt autonomously.
Vuong Dinh Trung, Jiaxiang Yi, Hieu Nguyen‐Duc, Tien Nu Hoang Lo, Weili Zhao, Chaoqun Dong, Fabien Sorin, Baris Caglar, Lei Wei, Tung Nguyen‐Dang   +9 more
wiley   +1 more source

PROBLEMS OF THE AGREEMENT ON CUSTOMS VALUE OF GOODS AND TRANSFER PRICE IN FOREIGN ECONOMIC CONTROLLED OPERATIONS OF THE ENTERPRISES OF UKRAINE

Aktualʹnì Problemi Rozvitku Ekonomìki Regìonu, 2019
With the integration of the national economy into the global economic space, significantly are growing the volumes of foreign economic operations, most of which are carried out between related enterprises. Such operations are at the same time the subject
Iryna Pryimak, Vira Kmit, Yurii Hryshchyshyn   +2 more
doaj   +1 more source

Allocating common costs of multinational companies based on arm's length principle and Nash non-cooperative game

, 2020
International audienceAllocating common costs among the subsidiaries of multinational companies (MNCs) is widely conducted in practice. It is of paramount importance that optimal allocation plans can be developed.
Zhang, Linda, Li, Yongjun, Lin, Lin, Dai, Qianzhi   +3 more
core   +1 more source

Tailoring Phonon‐Driven Responses in α‐MoO3 through Isotopic Enrichment

Advanced Materials, EarlyView.
ABSTRACT The implementation of polaritonic materials into nanoscale devices requires selective tuning of parameters to realize desired spectral or thermal responses. One robust material, α‐MoO3, an orthorhombic crystal boasting three distinct phonon dispersions, provides three polaritonic dispersions of hyperbolic phonon polaritons (HPhPs) across the ...
Thiago S. Arnaud, Ryan W. Spangler, Johnathan D. Georgaras, Jonah B. Haber, Daniel Hirt, Maximilian Obst, Gonzalo Álvarez‐Pérez, Mackey Long III, Felix G. Kaps, Jakob Wetzel, Courtney Ragle, John E. Buchner, Youngji Kim, Aditha S. Senarath, Richarda Niemann, Mingze He, Giulia Carini, Unai Arregui‐Leon, Akash C. Behera, Ramachandra Bangari, Nihar Sahoo, Niels C. Brumby, J. Michael Klopf, Martin Wolf, Lukas M. Eng, Susanne C. Kehr, Thomas G. Folland, Alexander Paarmann, Patrick E. Hopkins, Felipe Jornada, Jon‐Paul Maria, Joshua D. Caldwell   +31 more
wiley   +1 more source

The Non-Neutrality of the Arm's Length Principle with Imperfect Competition [PDF]

, 2019
The Arm's Length Principle (ALP) has been broadly adopted by OECD countries to avoid the use of firms' internal transfer pricing as a device for shifting profits into low tax jurisdictions.
Lemus Torres, Ana Belén, Moreno, Diego
core