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Managerial Finance, 1982
In this paper the main objectives of transfer pricing are discussed as well as methods that have been suggested for each objective to be achieved. Also investigated are the interrelationships among transfer pricing objectives, methods, and circumstances under which companies ...
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In this paper the main objectives of transfer pricing are discussed as well as methods that have been suggested for each objective to be achieved. Also investigated are the interrelationships among transfer pricing objectives, methods, and circumstances under which companies ...
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Transfer Pricing Horizon in Brazil: Arm’s Length Standard and the Resale Price Less Profit Method
International Transfer Pricing Journal, 2021In this article, the authors seek to demonstrate, through an overview of the Brazilian resale price less profit method, that the convergence of the Brazilian transfer pricing rules to the OECD standard will depend not only on a comprehensive reformulation of the existing domestic legislation, but also a radical change in the country’s posture and tax ...
E.Barboza Muniz, P. Grillo
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Optimal Transfer Pricing Method and Fixed Cost Allocation
Abacus, 1996Prior empirical research on transfer pricing only reported what firms do but seldom explained why. This study moves the research forward by introducing hypothesis testing.Atkinson (1987) shows that pricing transfers at variable cost when capacity is in excess. as prescribed by economic theory.
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Developments Regarding the Transfer Pricing Method for Exports of Commodities
International Transfer Pricing Journal, 2014The author considers developments and advantages in the use of the PECEX method, which is used to determine transfer prices for exports of commodities, as well as challenges taxpayers may still face when applying this method.
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Legal Fundamentals of Selection of a Transfer Pricing Method
Business securityThe article discusses Russian transfer pricing methods, as well as the specifics of their application for assessing tax liabilities. The circumstances are considered, the analysis of which is necessary for the correct choice and application of transfer pricing methods.
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Prioritizing Transfer Pricing Methods: An Indian and Global Perspective
International Transfer Pricing Journal, 2015The author analyses the priority given to various transfer pricing methods from an Indian perspective, as well as from the perspective of the OECD and various countries around the world.
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Transfer Pricing: Is the Comparable Uncontrolled Price Method the Best Method in all Cases?
ACTA UNIVERSITATIS DANUBIUS. OECONOMICA, 2012The transfer price scope is becoming a very important issue for all companies that comprise from different departments or have a network of branches. These companies are obliged to present the way of price determination for transactions that they have with their branches or other relevant members of their network. The establishment of the multinational
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The Economics of Transfer Pricing Methods & Management of Tax Risk
SSRN Electronic Journal, 2014In this paper I derive a straightforward condition, which I call the Arm’s Length Dual Condition (ALD), for a controlled price to be, or not to be, arm’s length. A proof of the validity of this condition is carried out with respect to the Resale Price, the Cost Plus and the Transactional Net Margin pricing methods and it shows that contrary to general ...
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Transfer Pricing System Based on the Method of Cash Flows Redistribution
Scientific Research and Development. Economics of the Firm, 2019The article describes the system of transfer pricing based on the method of cash flows redistribution, developed by the author. The article describes such concepts as transfer price, transfer pricing, transfer pricing system. Methodological tools of research: analysis, synthesis, system approach. The author used the method of cash flows redistribution,
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The Classification and Prediction of Transfer Pricing Methods using Discriminant Analysis
Managerial Finance, 1982An attempt is made in this paper to discriminate among four groups of transfer pricing methods namely: market price, cost, negotiation, and other methods, according to the transfer pricing objectives and other environmental issues (i.e. transfer pricing determinants).
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