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Challenging the reliability of comparables under profit-based transfer pricing methods

Accounting and Business Research, 2013
Under profit-based transfer pricing methods, the selection of comparable companies is essential if detection of transfer price manipulation is to be reliable. Comparative advantage as embedded in internalisation theory argues that foreign-controlled companies (FCCs) should, in the long run, display greater profitability than domestic-controlled ...
MURA, ALESSANDRO   +2 more
semanticscholar   +4 more sources

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.
John E. Baiden
openaire   +2 more sources

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.
A. Jain
openaire   +2 more sources

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.
openaire   +2 more sources

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.
M. Steyn
openaire   +2 more sources

Transfer Pricing Methods

, 2022
The Cabinet Regulation No. 677 “Regulation of the Application of the Provisions of the Corporate Income Tax Act” (effective from 01.01.2018) lays down the methods for determining the arm’s length value of transactions or the arm’s length price of goods ...
O. A. Kirova, N. Nazarov
semanticscholar   +1 more source

Pengaruh Pajak, Kepemilikan Asing, dan Ukuran Perusahaan Terhadap Transfer Pricing

Journal Of Business, Finance, and Economics (JBFE), 2023
The purpose of this study is to examine the effect of tax, foreign ownership and company size on transfer pricing. The data used in this study are secondary data and quantitative research methods.
Widya Anggraini   +3 more
semanticscholar   +1 more source

Cost-based transfer pricing with the existence of a direct channel in an integrated supply chain

Journal of Modelling in Management, 2021
Purpose This study aims to analytically explore the economic role of transfer pricing in a vertically integrated supply chain with a direct channel, specifically when it uses cost-based transfer prices, as is frequently observed in management practices.
Jumpei Hamamura
semanticscholar   +1 more source

The impacts of inventory in transfer pricing and net income: Differences between traditional accounting and throughput accounting

, 2021
This research proposes the Theory of Constraints (TOC) throughput accounting (TA) as an alternative management control mechanism in an international transfer pricing setting.
Gustavo da Silva Stefano   +4 more
semanticscholar   +1 more source

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