While there have been few decided cases under the 1995 Transfer Pricing regulations and the OECD Guidelines, it is clear by now that the transfer pricing problem is as bad as it ever was. That is why my co-authors Kimberly Clausing and Michael Durst…
Taxation Law
In this subdiscipline:
389 papers
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Access price regulation is used in telecommunications to prevent a vertically integrated firm, which controls an essential input, from raising the rivals' costs. When the authorities remove the access price as a strategic tool, it becomes optimal…
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Because of well-known difficulties encountered in implementing separate entity accounting and the arm's length principle (SA/ALP), some have suggested that formulary apportionment (FA) should replace that approach as the international standard for…
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ÍNDICE I Apresentação da disciplina e justificação da sua autonomia A Introdução: apresentação do problema central da disciplina .... 13 1. O conhecimento dos valores e critérios que limitam e conformam o Direito Penal a partir do texto…
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Obra sobre o moderno Direito Administrativo que trata, a partir do estudo do regime administrativo e dos princípios constitucionais e gerais que o informa, de seus institutos, como o regime dos servidores públicos, concessões e permissões, licitação…
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Thailand is an open economy that is dependent on international trade and investment. The government has been promoting the country as an attractive place for foreign investors for many years using measures such as tax incentives for certain…
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This paper presents suggestive evidence of income shifting in response to differences in corporate tax rates for a large selection of OECD countries. We use a new method to disentangle the income shifting effects from the effects of tax rates on…
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This book provides general guidance to the reader on a range of transfer pricing issues. Technical material is updated with each new edition and is correct as at 1 April 2007. In hard copy form, this 2008 edition is the latest development of a work…
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Taxpayers' willingness to cooperate with the state and its institutions, in general, and their willingness to pay taxes, in particular, depend on a variety of variables. While economists stress the relevance of external variables such as tax rate,…
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The current system of taxing multinational firms relies on separate accounting: firms account for earnings and costs in each location in which they operate. This system generates a large tax incentive to earn income in low-tax countries, and…
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Focuses on the arising interest on transfer pricing for the manufacturing industries in the OECD countries. Definition of transfer pricing; Advantages of transfer pricing; Application of transfer pricing rules to arms length principle.
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The Internal Revenue Service's Advance Pricing Agreement (APA) Program was established in March 1991 to avoid transfer pricing disputes by entering into prospective agreements with taxpayers regarding their transfer pricing. This article presents a…
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Tax authorities in a number of countries are faced with decreasing tax receipts and may look for additional tax revenue by scrutinizing transfer pricing arrangements established during more prosperous times. Many multinationals have established…
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The arm's length approach and the formulary apportionment methods fall short of obtaining a fair and reasonable allocation among taxing jurisdictions of the worldwide income of multinational enterprises. Perceived abuses of the present system are…
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Transfer pricing is the setting of prices for transactions inside multinational enterprises. Because transfer prices can be manipulated to avoid paying taxes, governments insist that these prices must be set as if the firms were at arm's length.…
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In recent years, technological advances in the areas of transportation and communication have facilitated the opening of new markets, an increase in intercompany cross-border transactions, and rapid globalization of trading transactions. As a…
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Recent economic developments, particularly the globalization of capital markets, has made enforcement of national income taxes increasingly difficult. These enforcement issues go beyond mere tax competition for real economic activities. Because of…
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The continued survival of the arm's-length principle depends on three elements: 1. Certainty - Taxpayers need certainty to comply with tax rules and if application of principles affecting tax liability is left to the discretion of a tax…
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Purpose â This paper first attempts to analyze the issue of brand proliferation by a monopolist allowing transfer pricing as a channel to bridge headquarters and brand divisions, and then to view how the headquarters uses transfer pricing as a…
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This article looks at the increasing use of soft laws in tax administration. The author explains the difference between soft law and other forms of law in addition to the ongoing evolution and the impact it has on taxpayers.
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Other ProfessionalDumon, Sablon & Vanheeswijck -
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