Results 301 to 310 of about 1,473,014 (342)

Transfer pricing as a company management tool

Moscow University Economics Bulletin, 2021
This article studies one of the most complicated and yet popular company management tools, the transfer pricing. The author considers the aims and purpose of transfer pricing, the formation of a transfer pricing system as a company management tool ...
E. Avtukhova
semanticscholar   +1 more source

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
openaire   +1 more source

Defenders of the status quo: making sense of the international discourse on transfer pricing methodologies

Review of International Political Economy, 2020
Over a third of international trade happens within, rather than between, corporations. This makes establishing transfer prices – the price of transactions within and between related corporations – pivotal, as it defines corporations’ tax bills.
Fritz Brugger, R. Engebretsen
semanticscholar   +1 more source

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 ...
openaire   +1 more source

Corporate governance, foreign operations and transfer pricing practice: the case of Indonesian manufacturing companies

International Journal of Business and Globalisation, 2020
This research investigated several factors that contribute to international tax avoidance using the transfer pricing mechanism for manufacturing companies listed on the Indonesian Stock Exchange.
Arie Pratama
semanticscholar   +1 more source

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.
openaire   +1 more source

Classification of transfer pricing systems across countries

, 2020
This paper analyses the characteristics of transfer pricing (TP) rules across countries to create a classification of TP systems based on regulatory similarities. We apply hierarchical clustering method for the analysis of 57 qualitative and quantitative
Alex A. T. Rathke, A. Rezende, C. Watrin
semanticscholar   +1 more source

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 ...
openaire   +2 more sources

High Court Finds TNMM More Appropriate than CUP Transfer Pricing Method

Asia-Pacific Tax Bulletin, 2018
This case note reviews the Bombay High Court’s finding in Principal Commissioner of Income Tax v. Amphenol Interconnect Private Ltd that the transactional net margin method was a more appropriate method than the comparable uncontrolled price method to determine the arm’s length price of goods traded, and commission payments made, between associated ...
A. Dugar, L. Bhandari
openaire   +1 more source

TRANSFER PRICING METHODS: IMPLEMENTATION, POSITIVE AND NEGATIVE SIDES

2021
Dünyadaki küreselleşme bütün sosyal alanları etkilediği gibi ekonomik ilişkileri ve işlemleri de yoğun şekilde etkilemektedir. Ekonomik alandaki bu etkinin önemli sonuçlarından birisi de şirketlerin mal ve hizmet satışlarından en yüksek fayda (kardan daha geniş anlamda kullanılmıştır) sağlayacak fiyatı tespit etmeye yönelik uyguladıkları transfer ...
openaire   +1 more source