Results 11 to 20 of about 1,001 (216)
Practical Application of Art. 9 OECD Model Convention: the Czech Republic
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
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Documentation of Transfer Pricing Transactions in the Accounting System of Multinational Enterprise Groups [PDF]
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
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Transfer Pricing Methods for Services and the Policy of Fixed Length Principle
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
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Transfer pricing and safe harbours
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
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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
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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
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The Impact of Transfer Pricing on the Company’s Image. Implications in Audit Work [PDF]
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 +2 more
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This article describes the historical development of media policy in Greenland, and the shifts in the underlying normative and causal ideas that legitimise media policy.
Ravn-Højgaard Signe
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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
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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
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