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Transfer pricing as a method of tax planning. Business purpose rule

Economic Theory and Law
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The Transactional Net Margin Method : A transfer pricing method in theory and practice

, 2009
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Transfer pricing – definition and methods [PDF]

, 2019
Abstract: Transfer prices refer to the terms and conditions which so called “associated enterprises” agree for their “controlled transactions.” Examples of such transactions are the provision of management services, the supply of goods and the provision of loans.
Gorgieva-Trajkovska, Olivera, Georgieva Svrtinov, Vesna, Dimitrova, Janka, Koleva, Blagica   +3 more
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Transfer pricing methods in the context of intangible property

South African Journal of Accounting Research, 2004
The purpose of this study is to evaluate the suitability of existing acceptable transfer pricing methods and their application to international transactions between related parties involving intangible property, more specifically intellectual property that is legally protected.
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Cost-based transfer pricing [PDF]

Review of Accounting Studies, 2011
This paper compares the performance of alternative cost-based transfer pricing methods. We adopt an incomplete contracting framework with asymmetric information at the trading stage. Transfer pricing guides intra-company trade and provides incentives for
Thomas Pfeiffer, Ulf Schiller, Pfeiffer Thomas   +2 more
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Transfer Pricing Methods

2019
When a company operating in China under foreign ownership sets out to comply with the prevailing regulations over transfer pricing, it is able to choose an appropriate pricing method from a range of five. All these methods are used to assist a company in China to identify the required arm’s length price for any traded asset imported from, and exported ...
Jian Li, Alan Paisey
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Transfer Pricing Methods for Services

SSRN Electronic Journal, 2018
This paper is about the methods which used in services. Thereupon, we have an analysis about the ways that a company which participates in controlled transactions of transfer pricing can tackle tax issues using the appropriate method. Services should comply with the requirements of the arm’s length principle.
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Transfer Pricing Methods and Benefits

SSRN Electronic Journal, 2011
Transfer pricing refers to the ‘transfer price, intra corporate price, or the price of a good or service sold by one affiliate to another, the home office to an affiliate or vice verse’. [1]There are two types of Exports in goods and services in International Trade.
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Simplification in Transfer Pricing

Florida Tax Review, 2021
It is the aim of this contribution to sustain that, despite the inherent complexity that the enforcement of the arm’s length rationale entails, it is feasible—and desirable—to introduce simplification measures without abandoning this worldwide accepted standard, especially in the context of developing countries and despite reticence shown by ...
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