Results 11 to 20 of about 2,981,091 (241)

Emerging Perspectives on the Evolving Arm’s Length Principle and Formulary Apportionment [PDF]

, 2019
A decade ago, the arm’s length principle on which transfer pricing rules and practices are based, was entrenched, and suggestions for change minimal and largely dismissed by practitioners.
LM Oats (21840974), H Rogers (7784120)
core   +7 more sources

Standard Arm’s Length – w niewoli dogmatu: [Arm’s Length Principle – in bondage to dogma]

, 2023
It will be soon one hundred years since the arm’s length principle (ALP) was introduced. During the past century, the standard has become one of the foundations of the international tax order.
Lipka, Krzysztof
core   +1 more source

Practical Application of Art. 9 OECD Model Convention: the Czech Republic

Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis, 2014
All transfer prices determined between the associated enterprises must comply with the arm’s length principle. The arm’s length principle for associated enterprises is mentioned in Art.
Veronika Solilová
doaj   +1 more source

Documentation of Transfer Pricing Transactions in the Accounting System of Multinational Enterprise Groups [PDF]

Облік і фінанси
External factors and the complexity of the internal organizational structure can significantly affect the collection of evidence (information), which is the basis for assessing the compliance of controlled transactions with the arm's length principle by ...
Tetyana Storozhuk, Artem Morhunenko
doaj   +1 more source

Transfer Pricing Methods for Services and the Policy of Fixed Length Principle

Economics and Business, 2019
The paper deals with the methods used by companies for controlled transactions in services. The author performs an analysis of the ways a company that takes part in controlled transactions of transfer pricing can tackle tax issues using an adequate tax ...
Challoumis Constantinos
doaj   +1 more source

Transfer pricing and safe harbours

Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis, 2013
Transfer prices are significant for both taxpayers and tax administrations because they determine in large part taxable profits of associated enterprises in different tax jurisdictions.
Veronika Solilová
doaj   +1 more source

Concept and application of the arm’s length principle [PDF]

, 2017
ERHAN, Lica, EFIMENCO, Olesea, DARANUȚA, Inga. Concept and application of the arm’s length principle. In: Conferinţa Ştiinţifică Internaţională Studenţească "Provocările contabilităţii în viziunea tinerilor cercetători" [online], 17 martie 2017 ...
Daranuța, Inga, Erhan, Lica, Efimenco, Olesea   +2 more
core   +1 more source

Analysis Method of Transfer Pricing Used by Multinational Companies Related to Tax Avoidance and its Consistencies to the Arm's Length Principle

Binus Business Review, 2015
The purpose of this study is to evaluate about how Starbucks Corporation uses transfer pricing to minimize the tax bill. In addition, the study also will evaluate how Indonesia’s domestic rules can overcome the case if Starbucks UK case happens in ...
Nuraini Sari, Ririn Susanti Hunar
doaj   +1 more source

ASSESSMENT OF THE PRE-CONDITIONS FOR THE IMPLEMENTATION OF MODERN TECHNOLOGIES OF TAX CONTROL ON BASE EROSION AND PROFIT SHIFTING

Соціальна економіка, 2022
The purpose of the study is to assess the possibility of combining the concepts of transfer pricing, beneficial owner of income and valid business purpose in a model of three-component tax risk assessment for countering BEPS. To achieve this purpose, the
Dmytro Nosenko
doaj   +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