Results 11 to 20 of about 85,170 (253)

Why Is It Challenging to Apply Arm’s Length Principle on Intragroup Financing in Indonesia? A Tax Officials Perspectives

Jati
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
doaj   +2 more sources

THE ARM’S LENGTH PRINCIPLE: A PANACEA OR PROBLEM TO REGULATING TRANSFER PRICING TRANSACTIONS BY MNES IN DEVELOPING COUNTRIES

Eurasian Journal of Business and Management, 2022
Transfer pricing manipulation by multinational enterprises is a big problem in developing countries, considering the increased levels of tax avoidance and evasion in these countries.
Favourate Y. Mpofu, Eukeria Wealth
semanticscholar   +1 more source

Arm's Length Principle Analysis on Tax Avoidance through Transfer Pricing Post- Pandemic (Covid-19): A Proposed Study

KnE Social Sciences, 2023
The Covid-19 pandemic has forced society to adapt to technological advancement and decision-making behavior in corporate management. In response, companies implemented transfer pricing strategy to ease the tax burden in order to optimize expenditure ...
Natalina, Apollo
semanticscholar   +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

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

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

Media policy in Greenland

Nordicom Review, 2021
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
doaj   +1 more source