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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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The Relationship between Transfer Pricing Objectives, Company Operating Circumstances and Transfer Pricing Methods

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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Transfer Pricing Horizon in Brazil: Arm’s Length Standard and the Resale Price Less Profit Method

International Transfer Pricing Journal, 2021
In 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, 1996
Prior 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, 2014
The 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 security
The 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, 2015
The 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, 2012
The 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, 2014
In 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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