Dissertations / Theses: 'Transfer pricing'

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Gesua', Sive Salvadori Davide <1993&gt. "Transfer pricing." Master's Degree Thesis, Università Ca' Foscari Venezia, 2017. http://hdl.handle.net/10579/10654.

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Möllerstedt, Lena. "Transfer Pricing : Svenska domstolars tillämpning av OECD Transfer Pricing Guidelines vid armlängdsprisberäkningar." Thesis, Jönköping University, JIBS, Commercial Law, 2005. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-359.

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Ren, Linghui, and 任凌晖. "Transfer pricing in China." Thesis, The University of Hong Kong (Pokfulam, Hong Kong), 2010. http://hub.hku.hk/bib/B45157819.

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Tisa, Pornprapa. "The Transfer Pricing Act of Thailand : Critical Comparison with the OECD Transfer Pricing Guideline." Thesis, Uppsala universitet, Juridiska institutionen, 2019. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-384504.

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Lindman, Carl-Johan. "Tax Penalties in Transfer Pricing." Thesis, Uppsala universitet, Juridiska institutionen, 2019. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-389627.

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The purpose of this thesis is to examine both the conditions for levying tax penalties in transfer pricing and the sustainability of the Swedish tax penalty framework in regard to transfer pricing in a post-BEPS world. This question is of relevance as BEPS has resulted in more extensive documentation requirements, affecting both the tax payer’s tax assessment procedure and the Swedish Tax Agency’s auditing practice. Tax penalties were introduced in order to incentivize the tax payer to disclose relevant information for the tax assessment. The scope of relevant information is relative to the correction rule, which has a significant connection to the OECD and BEPS. This thesis concludes that in a post-BEPS world, relevant information relates to domestic developments of the correction rule produced by the legislator, case law and the Swedish Tax Agency. Furthermore, this thesis concludes that transfer pricing documentation in full compliance with the Swedish content requirements should greatly mitigate a tax payer’s risk of being subjected to tax penalties. Court rulings from the lower administrative courts regarding tax penalties in transfer pricing demonstrate contradictory views to that of statutory law, case law and preparatory works. These opposing views constitute the current framework of tax penalties in transfer pricing, which is neither sustainable nor appropriate. For this reason, the Swedish tax system requires either extensive case law or statutory reform on the subject. This thesis concludes that statutory reform would perhaps be the most appropriate development in light of certain aspects of the principle of legality. Proceeding from that conclusion, this thesis therefore presents two amendments to the Swedish tax penalty framework in regard to transfer pricing.

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Catalani, Matteo <1993&gt. "Transfer Pricing in multinational groups." Master's Degree Thesis, Università Ca' Foscari Venezia, 2019. http://hdl.handle.net/10579/15814.

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L'elaborato si pone l'obiettivo di approfondire il tema dei transfer pricing all'interno dei gruppi multinazionali. Partendo dall'ambito di applicazione dei prezzi di trasferimento, fino ad arrivare ai metodi di determinazione dei prezzi stessi.

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Wu, Ronald. "Transfer Pricing: Current Problems and Solutions." Scholarship @ Claremont, 2010. http://scholarship.claremont.edu/cmc_theses/87.

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The current problems and possible solutions surrounding United States transfer pricing regulations are discussed and studied. The schemes large multinational companies are implementing to legally evade taxes are uncovered as the financial effects to the United States Treasury and government are becoming material. The benefits for these schemes are financially advantageous for corporations as they are able to report larger profits and higher returns for investors. But this is being done at the expense of our government. Corporations are finding ways to escape the high U.S. corporate tax rate and lower their global tax liabilities by allocating income to lower tax jurisdictions. Tax havens like Ireland or Bermuda are popular to have subsidiaries which hold a corporations intangible property. Five United States Tax Court cases concerning transfer pricing are studied and the outcomes are analyzed. The current problems studied from these cases are, shipping intangible property, valuing intangible property, the arm’s length standard. The possible solutions to these currents problems are by no means easy to solve and no one revision can relieve all the problems. The arm’s length standard is the corner stone to the current problems and if the government can find a way to better enforce the standard or replace it, it will be a large step in the right direction.

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Abu-Serdaneh, Jamal Abdel-Rahman. "Transfer pricing in UK manufacturing companies." Thesis, University of Huddersfield, 2004. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.405183.

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Quan, Lianfeng. "Funds transfer pricing and performance evaluation." Thesis, Bangor University, 2009. https://research.bangor.ac.uk/portal/en/theses/funds-transfer-pricing-and-performance-evaluation(dffbe8e5-21f4-4179-b123-b86f4b2fa3b6).html.

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Funds transfer pricing (FTP) is a management accounting technique used to identify the source of profits contributions for business units and products, and is a strategic tool to integrate risk management with decision-making. As very few studies have investigated the FTP model for commercial banks, this thesis attempts to identify the factors driving the bank FTP model and to develop the model. To develop the bank FTP model, the bank FTP process, which consists of the WHY, the WHAT, the WHO, the WHERE, the WHEN and the HOW factors, is designed. The WHY factor determines that the FTP model should be developed to enhance effective bank risk management process, and properly assign profit contributions within a bank to help achieve accurate bank performance evaluation. The WHERE factor demands that the FTP model should be developed at the bank business unit and instrument levels, and the WHEN factor requires that both the original and remaining term FTP models should be developed. The FTP model is developed with the responsibility accounting principles and financial risk management techniques, which are applied for the WHO, the WHAT and HOW factor design. The implications of the FTP model developed in this thesis are examined by applying the model in bank performance measurements. The FTP model is found to be able to properly assign bank risks to business unit managers who have control over the risks, and properly allocate profit contributions within a bank. The FTP model is also applied in the different types of banks, which have varying degrees of decentralization of risk management decision-making authority. It is found that the FTP model can achieves effective risk management and accurate business performance evaluation in the partially decentralized bank. The case study analysis of the FTP model in the Chinese bank shows that the bank FTP model developed in this thesis is more effective in risk management than the bank's FTP method.

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Kanee, Emmanuel Lah. "Strategies to Manage Transfer Pricing Risks." ScholarWorks, 2019. https://scholarworks.waldenu.edu/dissertations/7812.

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Transfer pricing compliance related issues continue to pose challenges to leaders of multinational entities (MNEs) and tax regulators. MNE leaders strive to mitigate the risks of non-compliance violations and double taxation, while tax regulators seek to minimize profit shifting and revenue losses. This multiple case study explored strategies for managing transfer pricing risks against the backdrop of various risks MNE leaders face for non-compliance violations. The cost contribution agreement theory served as the conceptual framework for this study. Data were collected from organizational documents and semistructured interviews conducted with 6 finance executives representing 2 multinational entities in the midwest and southwest regions of the United States who have implemented successful strategies to manage transfer pricing risks. Data were analyzed using Yin's multiple-step thematic analysis process. Following the thematic data analysis 5 themes emerged, including commitment to tax compliance, tax minimization, advance pricing agreement (APA), comparable uncontrolled price method (CUP), and cost plus method (CPM). MNE leaders favor commitment to tax compliance as an effective strategy as penalties for non-compliance increases risks to business functionality. The findings of this study may help business leaders to follow compliance procedures and adopt risk mitigation strategies, while also informing regulators to update tax regulations to reflect current economic realities. The findings of this study could result in positive social change through an enhanced governmental revenue that stimulates economic growth, improves productivity, and promotes technological innovations.

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Lagerqvist, Johan, and Yan Cheng. "Documentation within Transfer Pricing : A case study." Thesis, Jönköping University, JIBS, Business Administration, 2009. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-9713.

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Purpose: The overall purpose of this thesis is to provide an analysis of the effects of the documentation requirements on transfer pricing and provide a clearer picture of the documentation requirements in transfer pricing. Furthermore, the purpose is to analyze whether the chosen method of Superfos is adequate related to the new regulations.

Background: In 2007, new regulations concerning the documentation of transfer pricing was enacted in Swedish law based on OECD guidelines. This change has led to new internal guidelines for companies regarding their transfer pricing work since the requirements apply to both Swedish owned companies and foreign owned companies. Furthermore, with this change, a great uncertainty about the requirements is shared by companies.

Method: This thesis has been conducted as a qualitative case study with Superfos as the case company. A deductive approach has been used and the collection of data consists of both primary and secondary data. Primary in the form of an interview with the finance manager at Superfos and secondary through the use of the Swedish tax authority's stated guidelines concerning transfer pricing as well as books, journals and databases.

Conclusion: In the conclusion we present a clarifying model of the documentation in transfer pricing based on the data collected for this thesis. In six steps, a clarifying picture of the overview, company structure, transactions identification, functional analysis, comparability analysis and results is provided.

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Liang, Kelly (Kelly JieRu). "Optimized transfer-pricing model for Asia Pacific." Thesis, Massachusetts Institute of Technology, 2011. http://hdl.handle.net/1721.1/68894.

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Thesis (M. Eng. in Logistics)--Massachusetts Institute of Technology, Engineering Systems Division, 2011.
Cataloged from PDF version of thesis.
Includes bibliographical references (p. 35).
Transfer price is an important field of study for profit maximization. As more multinational enterprises (MNEs) are involved in global trading in the recent decades, the objective to set an optimized transfer price is more crucial than ever since the difference in tax rates and tariffs have sophisticated impacts on the overall profit for the corporation. In this thesis, which focuses primarily on Asia Pacific, I will review historical transfer pricing methods, explore the factors that affect transfer price determination, and construct a mathematical model to determine the optimal transfer price by comparing and contrasting the different transfer pricing methods with data from a hypothetical company. Particularly, I will illustrate the effects of taxes and tariffs on the determination of transfer price. Consequently, I will perform sensitivity analysis with respects to tariffs, taxes, and shipping costs. The thesis will conclude with recommendations on the optimized transfer pricing methods and insights on the implications for the method.
by Kelly Liang.
M.Eng.in Logistics

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Linnell, Erika. "Transfer Pricing : Approaching and Aligning Intangible Assets." Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Juridik, 2015. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-28681.

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Sriausadawutkul, S. (Sirikwan). "Transfer pricing and its implementation in Thailand." Master's thesis, University of Oulu, 2013. http://urn.fi/URN:NBN:fi:oulu-201309251718.

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This paper studies how transfer pricing practice is actually taken in Thailand. Though there has been researched on transfer pricing in Thailand, we have found that such research are focused on related law and regulation not on its practice, itself. Therefore, this research aims to focus on the practice of transfer pricing and its related facts. Our research finds that many taxpayers are still unaware of transfer pricing as the result of no legal enforcement on such practice. Furthermore, we find that businesses with persistent loss and profit margin lower than industry average, assuming there is substantial related-party transaction, will catch the tax officers’ attention. Similar to other researches, we find that TNMM is mainly used to test the arm’s length price when it comes to transfer pricing audit. Not surprisingly, we find that compliance risk is biggest concern when implementing transfer pricing as the result of stiff penalty imposed by tax authorities. Such penalty can be greatly affect shareholders’ value; therefore, to mitigate such risk, it is recommended that MNEs shall have a good transfer pricing documentation on hand or enter APA program when necessary.

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Železný, Stanislav. "Problematika transferových cen (Issues of Transfer Pricing)." Master's thesis, Vysoká škola ekonomická v Praze, 2011. http://www.nusl.cz/ntk/nusl-81865.

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The aim of the thesis is to approach the issues of transfer pricing, both in terms of legislation, and especially from the perspective of maker of Transfer pricing Documentation and from a practical point of view to analyze the most often transaction between related parties. The thesis is divided into four parts. The first part deals with transfer pricing legislation and provides a general overview of publicity available documents and legal regulation related to transfer pricing issues in the Czech Republic. The second part deals with general and practical look at the Documentation that is used as evidence of transfer prices for tax control. The third part describes transfer pricing methods in detail, which are recommended by OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration. The last part analyzes the most often transactions between related parties and provides particular examples from practice experience.

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Bordin, Monica <1988&gt. "ONERI DOCUMENTALI IN MATERIA DI TRANSFER PRICING." Master's Degree Thesis, Università Ca' Foscari Venezia, 2013. http://hdl.handle.net/10579/2366.

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La tesi tratta gli oneri documentali in Italia in materia di transfer pricing. L’art 26 del D.L. 31 maggio 2010, n.78 convertito con modificazioni nella legge 30 luglio 2010, n.122 e intitolato “Adeguamento alla direttive OCSE in materia di documentazione dei prezzi di trasferimento”, ha introdotto in Italia un regime documentale in materia di prezzi di trasferimento allineando il paese alla maggior parte delle nazioni europee che da tempo avevano predisposto nei loro ordinamenti tale disciplina. Secondo tale disposizione il contribuente che fornisce all’Amministrazione finanziaria la documentazione idonea a provare la conformità al valore normale dei prezzi praticati nelle operazioni infragruppo e ne dà comunicazione all’Amministrazione Finanziaria, è esonerato dalle sanzioni amministrative per infedele dichiarazione di cui al comma 2, art.1 del D.Lgs. 18 dicembre 1997, n. 471, restando accertabile in capo allo stesso solo la maggiore imposta. Il Legislatore ha voluto inserire un onere in luogo di un obbligo per sollecitare l’adeguamento spontaneo del contribuente. Le indicazioni utili al fine di redigere la documentazione idonea e le modalità di comunicazione del possesso sono contenute nel Provvedimento dell’Agenzia delle Entrate del 29 settembre 2010 e nella successiva Circolare della stessa Agenzia del 15 Dicembre 2010 n.58/E che integra i contenuti del Provvedimento. In particolare il Provvedimento, nel definire i contenuti della documentazione, indica al contribuente una struttura formale rigida e divisa in paragrafi e sottoparagrafi. I documenti richiesti sono il Masterfile che deve essere redatto dalla capogruppo e contenere una descrizione del gruppo in generale e la Documentazione nazionale che deve essere predisposta da ogni singola impresa del gruppo e giustificare il valore normale dei prezzi delle transazioni infragruppo. La presente tesi, dopo una rapida disamina del contesto internazionale in cui il Provvedimento si inserisce, si propone di analizzarne le disposizioni, individuando in maniera specifica i contenuti della suddetta documentazione, i soggetti onerati e gli adempimenti formali a questi ultimi richiesti. La tesi si propone inoltre di approfondire le ragioni che hanno spinto il legislatore ad introdurre il regime premiale e porre una riflessione su quali siano i vantaggi e gli svantaggi in capo al contribuente nell’adeguarsi a tale onere.

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Gallocchio, Matilde <1993&gt. "IL TRANSFER PRICING IN ITALIA:UNA ANALISI EMPIRICA." Master's Degree Thesis, Università Ca' Foscari Venezia, 2018. http://hdl.handle.net/10579/12655.

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Il successo di un'impresa è determinato dalla performance nei confronti dei diversi attori verso i quali essa si interfaccia, pertanto la valutazione di quest'ultima diventa imprescindibile. In particolare un'impresa può rivolgersi, non solo verso i mercati esterni ma anche interni. Per quanto riguarda i secondi il prezzo di trasferimento e la sua valutazione giocano un ruolo cruciale, anche a seguito della crescente internazionalizzazione delle imprese, non solo di grandi dimensioni ma anche delle nostre PMI. Si tratta di un istituto estremamente complesso da gestire a livello pratico soprattutto a seguito dei notevoli cambiamenti subiti dai mercati negli ultimi vent'anni.In particolare il contesto italiano, caratterizzato da un'elevata pressione fiscale, si presta particolarmente a favorire manipolazioni di prezzi che difficlmente possono essere regolate dal mercato, come, invece, vorrebbe l'arm's lenght principle indicato dalle Guidelines OCSE. Il fine di tale elaborato è quindi analizzare e spiegare il fenomeno del transfer pricing, tramite un'analisi empirica condotta a livello italiano nel settore manifatturiero. Attraverso l'utilizzo di un campione significativo di imprese a controllo straniero (ICS) e a controllo nazionale (ICN) l 'obiettivo è quello di verificare se anche in Italia le ICS realizzano politiche di transfer mispricing, come evidenziato da altri studi empirici su imprese operanti in territori esteri.

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Rahnamafar, Mahabad. "The transfer pricing methods’ applicability when determining the transfer price of intangible property : based on Swedish legislation and the OECD Transfer Pricing Guidelines." Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Redovisning och Rättsvetenskap, 2011. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-15204.

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Terzioglu, Bulend, and bulend terziogluu@acu edu au. "Domestic Transfer Pricing in Services: A Value Chain Framework." RMIT University. Accounting and Law, 2007. http://adt.lib.rmit.edu.au/adt/public/adt-VIT20080529.150135.

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The question of the management of the transfer process and transfer pricing is an important one for managers and academics alike (Colbert and Spicer, 1995). Yet, in general, our current knowledge on several aspects of transfer pricing process is limited. One question which arises in relation to transfer pricing in service organizations is whether there is an association between the transfer price and the internal customer's perception of value emanating from the transaction. An inappropriate transfer pricing system can give rise to a number of adverse effects which can include among other things, maldistribution of economic resources, negative motivation for reducing costs (Lesser, 1987), lack of goal congruence and inequitable performance evaluation (Cravens and Shearon, 1997). The gap in the literature on transfer pricing in the service sector applies equally in the Australian setting. This is despite the significant and increasing contribution of the service sector to both GDP and employment. The objective of this research is to explore the domestic transfer pricing practices of service organisations in Australia with the emphasis placed on examining whether, in internal transactions, the domestic transfer price had any influence on the value perceived by the internal buyer. Because the extant transfer pricing theories cannot explain the value perceived by the internal customer in internal exchange of goods and services, an exploratory research methodology is adopted and no assumptions are made about the relationship. PDF created with pdfFactory trial version www.pdffactory.com 3 Data were gathered from survey responses from eighty service organisations and thirteen face-to-face interviews. Survey data were sought at two levels. Questions of a strategic nature were directed to corporate management while questions pertinent to transfer pricing and value were sought from the divisional management who are actually involved in such transfers. Exploratory factor analysis was used to analyze the data. The findings indicate that cost-based transfer pricing was the most preferred method, and in internal transactions, and responsiveness of the internal supplier was the key factor for internal buyers. The research found that service organisations are external customer oriented and internal customer issues are secondary. The research results also demonstrate that no significant association exists between transfer pricing and internal customer perceived value. The current research contributes to the transfer pricing literature by providing insights to locus of transfer pricing decisions, transfer pricing methods employed by service organizations in Australia, objectives of transfer pricing systems, conflicts arising during from the transfer pricing process and the role of transfer prices on the value perceived by internal customers. As a research topic, this study is pioneering as it integrates for the first time, the constructs of transfer price and value in internal transactions. Another unique feature of this research is that it was carried out in another important but under-researched context of service organisations.

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Arsenovic, Dusan. "Transfer Pricing of Internal Banks : In the Light of Fiat State aid Case and Transfer Pricing Guidelines onFinancial Transactions." Thesis, Uppsala universitet, Juridiska institutionen, 2020. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-414537.

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Singh, Ranjit. "The review of the Glaxo decision and topical issues in transfer pricing a dissertation submitted to Auckland University of Technology in partial fulfilment of the requirements for the degree of Master of Business (MBus), June 2008." Abstract. Full dissertation, 2008.

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Quttineh, Yousef. "Transfer Pricing Profit Split Methods : A Practical Solution?" Thesis, Jönköping University, JIBS, Commercial Law, 2009. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-11107.

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The purpose of this master’s thesis is to explain and analyze whether today’s existing regulations provide sufficient guidance on how to apply the Profit Split Method (PSM) in practice. Since the enterprises’ profits arising from intra-group transactions increases, the tax base for any government also becomes larger and more important. This issue will likely become even more problematic as the globalization branches out and the majority of the global trade is undertaken between associated enterprises.

In order to satisfy all parts and serve the dual objective of securing an appropriate tax base in each jurisdiction and avoiding double taxation, one ambition of the OECD is to harmonize the transfer pricing rules and make them become more uniform. An area in which this goal can be accomplish is at an international level such as the OECD; an important developer in the field of transfer pricing. Different transfer pricing methods has been developed which can be applied by both taxpayers and tax authorities to determine a correct transfer price. Six of these methods has gained international acceptance, although to a more or less extent among various countries, and one of these methods is the PSM. In the years between 1979 and 1995, the OECD had a reluctant standpoint of accepting the application of any transfer pricing method based on profits, such as the PSM. This hesitant viewpoint changed in the existing TPG which explicitly stipulates that the PSM could provide a transfer pricing estimation in accordance with the ALP, which should be accepted in exceptional cases.

There are certain situations where a PSM possibly will provide the most appropriate arm’s length result. Since the principle of economics can create complex business environments of both vertical and horizontal integration, contributions of valuable intangibles on both sides of the cross-border transaction, the PSM might be the only method which can be employed. A relevant issue which need to be enlightened is whether the existing guidance provided by the OECD and USA is sufficient from a practitioners and tax administration point of view, or is more guidance needed to better understand the issues surrounding the concept of the PSM. The fact that OECD insist of using comparables to the highest extent as possible when employing the PSM entails practical problems, since it is rather a rule than an exception that reliable comparables cannot be found when valuable intangibles are involved.

The Arthur of this master’s thesis has identified three key conclusions which might facilitate how PSM issues can be handled in the future and improve the existing PSM guidance. These conclusions are the need for a uniform PSM interpretation, the need for additional flexibility and acceptance, and the need for additional TPG guidance.

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Nakayama, Kiyoshi. "Transfer pricing taxation : Canadian perspective and Japanese perspective." Thesis, University of British Columbia, 1987. http://hdl.handle.net/2429/26143.

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For the last decades, transfer pricing has been one of the most important issues for both tax authorities and multinational corporations. On the one hand, tax authorities, despite their counter-measures, have not been able to cope with international tax avoidance or evasion using transfer pricing by multinational corporations owing to the deficiency of tax systems and the inability of tax administrations and this has resulted in a huge revenue loss to the coffers of their countries. On the other hand, while multinational corporations have been using transfer pricing as vehicles to maximize their overall after-tax profits as a group, they have been suffering intolerable administrative burdens and double taxation caused by enforcement of counter-measures by tax authorities. The basic principle for transfer pricing taxation legislation is the "arm's length principle", that transactions between parties that are not dealing at arm's length should be carried out for tax purposes under terms and at a price that one could reasonably have expected in similar circumstance had the parties been dealing at arm's length. This principle has been endorsed by the OECD, Canada, the U.S. and other developed countries, however, common specific guidelines under this principle have not been established among tax authorities and even multinational corporations themselves cannot always find an arm's length price acceptable to tax authorities. Since the OECD Committee on Fiscal Affairs issued the report "Transfer Pricing and Multinational Enterprises" in 1979, tax authorities, multinational corporations and tax practitioners have been making strenuous efforts to find a reasonable and practical transfer pricing taxation system and to coordinate its enforcement, all of which enables tax authorities to recover or keep their fair share of revenue and protect multinational corporations from double taxation. At present, the situation already shows some improvements due to efforts for the harmonization of guidelines among tax authorities, and due to multinational corporations' application of transfer pricing policy in a more self-restricted manner, and more appropriate advice from tax practitioners. However, there is still room for possible improvements. In Canada, there have been no guidelines other than the Income Tax Act which provides general principles of transfer pricing taxation, and actual enforcement has been based on the internal assessing guideline of Revenue Canada. But, on February 27, 1987 Revenue Canada issued Information Circular 87-2. Although an information circular does not carry any legal weight, it is expected that the circular will eliminate taxpayers' uncertainty and augment tax compliance. On the other hand, in Japan, despite its export-oriented economy, the Japanese tax authorities have not been keeping pace with the internationalization of economic activities. Having introduced anti-tax haven legislation in 1978, Japan in 1986 introduced transfer pricing taxation legislation. Although fairly concrete pricing methods have been written into legislation in order to permit the reasonable enforcement of the new system, there is much to be learned from the experience of the "advanced" countries. Above all, Canada's experience could be useful, as the provisions of the new Japanese transfer pricing taxation legislation are similar to those of the Canadian Income Tax Act and both countries have several similarities in terms of their relationship with the U.S. In this thesis, after reviewing the background to these problems, I will discuss the Canadian transfer pricing taxation system and its enforcement by looking at each type of intra-group transaction and the corresponding adjustment and mutual agreement procedure system. Then I will compare the Canadian approach and Japanese approach. Possible improvements will be dealt with in the conclusion. Since there has been little jurisprudence in this area, the discussions are primarily based on the tax authorities' perspectives and the OECD reports.
Law, Peter A. Allard School of
Graduate

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Zbychorski, Kamil Krzysztof. "Multinational Enterprises' International transfer pricing strategies in China." Thesis, University of Leeds, 2009. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.509879.

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Sandström, Richard, and Puja Karimzadeh. "Transfer Pricing Documentation : - In Need Of A Harmonization?" Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Rättsvetenskap, 2014. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-24019.

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In today's global world where internal cross-border transactions are made in a vast amount and thereby affect the economy to a large extent the area of transfer pricing has become more important than ever. Therefore the organization for economic co-operation and de-velopment (OECD) have started the base erosion and profit shifting project which aims to prevent the exploiting of gaps and differences of regulations in different states in cross-border transactions. Within this project the documentation requirements are discussed, more specifically a potential harmonization of the requirements. 30 July 2013 a white paper on the subject was published which led to a suggested draft for changes in the Chapter V of the OECD transfer pricing guidelines.This thesis aims to answer the question of whether or not there is a need for harmoniza-tion in the area of transfer pricing documentation and whether or not the purposed discus-sion draft fulfills the potential need in an appropriate manner. How this affect the Swedish documentation requirements is also asked. The Code of conduct on transfer pricing docu-mentation for associated enterprises in the European Union (EU TPD) is an existing form of harmonizing the documentation requirements which is also analyzed and to some extent compared to the suggested changes in the draft.The lack of harmonization in such a cross-border dependent area has shown to be prob-lematic and the possible gains for both taxpayers and tax administrations on a global basis suggests that a harmonization is desirable. Some aspects of the draft are still in need of clar-ification but all in all the draft is desired, the reactions of the industry also support this conclusion. The draft is moving towards a similar harmonization as the EU TPD and since the EU TPD is based on the current OECD transfer pricing guidelines it is inevitable to find clear similarities.

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Reis, Duarte Nuno Tenreiro Freitas dos. "The tension between Transfer Pricing and Customs Valuation." Master's thesis, Instituto Superior de Economia e Gestão, 2012. http://hdl.handle.net/10400.5/5139.

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Mestrado em Contabilidade, Fiscalidade e Finanças Empresariais
This master thesis intends to examine the tension between transfer pricing and customs valuation, showing how transfer pricing, in the context of corporate income taxation, and customs valuation, in the context of tariffs, are two realities that share a common starting point– the pursuant towards the achievement and corroboration of the arm’s length principle – but incorporate critical differences and inconsistencies. After summarily describing the theoretical highlights behind the structure of each discipline, we perform an in-depth comparative analysis on the interactions between transfer pricing and customs valuation, exploiting the issues that arise from the lack of convergence between these two systems, which might act as a burden for the taxpayer / importer and be a source of situations of double taxation. The work developed led us to the conclusion that convergence and harmonization is a desirable and necessary step. While concluding that a full convergence would be difficult to implement mainly due to structural focus and timing differences, an acceptable degree of convergence would be reached based on three main foundations: the harmonization of the mechanism of choice of method, the mitigation of timing and focus differences and the clarification of the process of reflecting post importation transfer pricing adjustment at the customs level.
O trabalho realizado pretende analisar a tensão existente entre preços de transferência e a valorização alfandegária, demonstrando que os preços de transferência, no contexto da tributação do rendimento das empresas, e a valorização alfandegária, no contexto da tributação aduaneira, são duas realidades que derivam de um ponto de partida comum – ambas as disciplinas procuram validar o princípio de plena concorrência nas operações vinculadas –, mas incorporam diferenças e inconsistências que se revelam críticas no resultado final obtido. Após descrição sumária dos princípios teóricos subjacentes, realizámos uma análise comparativa detalhada às interacções entre preços de transferência e a valorização alfandegária, com foco nas questões que estão na base da falta de convergência entre as duas disciplinas e que se revelam penalizadoras para o contribuinte / importador, podendo estar na origem de situações de dupla tributação. Concluímos que a convergência e harmonização destas realidades constituem passos necessários e desejáveis, embora atentas as diferenças identificadas, consideremos que a convergência total será de implementação difícil na medida que diferenças de natureza estrutural ao nível do foco e implementação temporal subsistirão. Um nível aceitável de convergência entre as duas realidades deverá basear-se na harmonização do procedimento de escolha do método; na mitigação de diferenças de foco e implementação temporal e na clarificação do procedimento de reflexo do ajustamento correlativo ao nível aduaneiro.

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Lord, Tristan Sacha. "Transfer Pricing in South African income tax law." Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/4656.

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'Transfer pricing continues to be, and will remain, the most important international tax issue facing MNEs.' The term 'transfer pricing' is used to describe arrangements involving the transfer of goods or services, at an artificial price, in order to transfer income or expenses from one enterprise to an associated enterprise in a different tax jurisdiction. This results in the income derived at for each enterprise being disproportionate to their relative economic contributions, and thus impacting the relevant tax jurisdictions' fair share of tax. Tax authorities are therefore focusing their attention on transfer pricing rules and practices to ensure the correct attribution of income and expenses of related-party transactions. Another key issue, closely related to transfer pricing, is that of double taxation. Multinational enterprises, engaging in cross-border transactions, are at risk of having a single source of income taxed in two jurisdictions as a result of an incorrect application of transfer pricing rules. The purpose of this research is to evaluate South Africa's approach to transfer pricing, as well as compare it to the approaches as adopted by selected countries, namely Australia, the United Kingdom and Canada, with the aim of identifying the areas that South Africa could learn from practices in foreign jurisdictions. Specific issues dealt with include acceptable transfer pricing methods for determining an arm's length price, documentation requirements and non-compliance penalties, the use of Advance Pricing Agreements ("APA"), and the effects of e-commerce in applying the arm's length principle. The first issue relates to the criteria for the selection of the most suitable method in ensuring an arm's length outcome. Because the South African market is considered to be lacking in comparables, compliance with the arm's length principle will be determined by evaluation of the facts and circumstances of each case. The second issue looks at the transfer pricing policy documentation required to be prepared, the benefits of preparing such documentation, and the imposition of penalties on taxpayers failing to do so. The lack of statutory documentation requirements and specific penalty provisions in the South African legislation is also addressed. The third issue evaluates the use of APAs in resolving transfer pricing disputes. This technique is adopted by Australia, the United Kingdom and Canada, and therefore an assessment is made, taking into account both advantages and disadvantages of the technique, to determine whether it would be beneficial to South Africa to be able to agree in advance to transfer pricing methods to be applied to transactions with connected parties, thus reducing the potential for expensive and time consuming disputes with the South African Revenue Service ("SARS"). The fourth and final issue explores the challenges facing tax jurisdictions as a result of an increase in electronic trade. The relevance of the arm's length principle is assessed and recommendations for South Africa are made.

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Eliasson, My, and Adam Mankowski. "Transfer Pricing in the Context of Strategic Congruence." Thesis, Uppsala universitet, Företagsekonomiska institutionen, 2017. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-324851.

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The most common approach towards transfer pricing has been purely economic or with focus on tax regulations. However, transfer pricing has developed to become a component of organizational strategy. This indicates a growing focus on transfer pricing from a managerial perspective. A well-functioning transfer pricing structure can enable increased operational efficiency. The purpose of this paper is to explain the alignment between transfer pricing methods and strategy. The alignment between corporate levels and divisions enhances a corporation’s possibility to obtain strategic congruence, and thereby competitive advantage to become a stronger player on the market. The research is conducted as a multi-level case study with both qualitative and quantitative data collection. The result stresses that the case firms transfer pricing design is based on managerial objectives, and uses market-based and negotiated transfer price policies. The result finds that the methods and the strategy are partly aligned, which contributes to the corporation’s overall performance. Although, due to the levels different perceptions of profit maximization some sub-optimization occurs.

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Rossi, Stefano <1985&gt. "TRANSFER PRICING POLICIES: LINEAMENTI TEORICI ED APPLICAZIONI TECNICHE." Master's Degree Thesis, Università Ca' Foscari Venezia, 2014. http://hdl.handle.net/10579/4158.

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Agostini, Gianmaria <1996&gt. "La disciplina del transfer pricing nei gruppi societari." Master's Degree Thesis, Università Ca' Foscari Venezia, 2021. http://hdl.handle.net/10579/19496.

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Il tema dei prezzi di trasferimento fra imprese infragruppo è da sempre stato un tema molto sentito da parte dell'OCSE, in quanto ritenuto un metodo per spostare i redditi del gruppo multinazionale in paesi a fiscalità privilegiata. il lavoro si concentra, primariamente, sulle definizione derivanti dalla normativa europea, dalla normativa italiana e portando un esempio di convenzione internazionale stipulata dall'Italia con uno stato estero. Successivamente, si sposta l'attenzione sul diritto sostanziale e procedurale della materia. in particolar modo, si definiscono la transfer pricing package e la penalty protection, spiegando come devono essere predisposte le relative documentazioni. Il terzo capitolo è interamente dedicato all'analisi di comparabilità e dei metodi applicati per la comparazioni delle transazioni infragruppo, riportando anche esempi pratici. infine, l'ultima parte dell'elaborato è dedicato all'applicazione del transfer pricing nei gruppi societari, includendo anche le relative stabili organizzazioni.

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Hjertberg, Ida, and Sanna Pettersson. "Strategic Transfer Pricing : The Art of Pricing Inter-company Transactions between Sweden and China." Thesis, Linköping University, Business Administration, 2010. http://urn.kb.se/resolve?urn=urn:nbn:se:liu:diva-58007.

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Background

International transfer pricing has been a highlighted issue during the last decades as country after country has revised and introduced new transfer pricing laws as a respond to the expanded globalization. Several countries are adopting similar approaches and the prime guiding principles are provided by the Organization for Economic Co-Operation (OECD). The international law as well as the laws of all 30 member countries is based on the OECD Guidelines.

Purpose

The purpose of this master’s thesis is to describe differences and similarities regarding the transfer pricing regulations in China and Sweden and to explain how a Swedish multinational enterprise (MNE) have to utilize and adjust their transfer pricing strategy when trading with group companies in China. The results then conclude into a step model for strategic transfer pricing.

Result

The differences between the regulations are mainly uncovered in the definition of associated parties and associated interest. The differences in the regulations are thus of minor importance and does not affect a Swedish MNE to any major extent. The challenging area is instead the conflict between the tax authority and the customs service. To enable this study, three Swedish MNEs are used as a case study. We discovered that all had very different transfer pricing strategies even though they are within the same industry and two of them even within same range of products. Out of this we made the conclusion that the strategy chosen is not just depending on what product or service you trade with but also the aim and purpose, the range of products and the structure of the company. International transfer pricing is a very complex issue that goes into nearly all business operations. The concept of transfer pricing can thus be broken down and simplified if the demands from the company is minor.

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Novikovas, Martynas. "Transfer pricing model for tax payers and tax administrators." Doctoral thesis, Lithuanian Academic Libraries Network (LABT), 2011. http://vddb.laba.lt/obj/LT-eLABa-0001:E.02~2011~D_20111122_102758-55280.

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The analysis of theoretical and empirical researches on transfer pricing was performed in the dissertation. This analysis enabled to distinguish the main transfer pricing areas and to define and supplement the transfer pricing concept. Based on the transfer pricing researches performed by foreign scientists and transfer pricing legislation the transfer pricing model was created and presented in the dissertation. This model can be applied by the tax payers who needs to determine the arm’s length transfer prices in practise (e.g. for sale of goods, provision of services, loans and other inter-company transactions) and for tax administrators who are controlling the compliance of transfer prices with the arm’s length principle in order to ensure that corporate profit tax is paid correctly to the state budget. The transfer pricing model can be used for various inter-company transactions (e.g. sales of goods, services, loans, etc.) for tax payers acting in various industries in countries where OECD guidelines are applied (including Lithuania). Moreover, evaluating the effectiveness of transfer pricing regulation in Lithuania the research was performed. Performing this research the author calculated and compared the taxable income to be received applying the arm’s length principle and the alternative principle – the formulary apportionment. Such research was performed the first time in Lithuania.
Disertacijoje „Sandorių tarp asocijuotų asmenų kainodaros modelis mokesčių mokėtojams ir mokesčių administratoriui“ nagrinėjama sandorių tarp asocijuotų asmenų kainodaros raida, reglamentavimas bei metodai. Disertacijoje atlikta užsienio šalių mokslininkų sandorių tarp asocijuotų asmenų kainodaros teorinių ir empirinių tyrimų analizė. Remiantis sandorių tarp asocijuotų asmenų kainodaros teisine baze bei užsienio šalių mokslininkų atliktų tyrimų rezultatais, sudaryta: sandorių tarp asocijuotų asmenų kainodaros nustatymo metodiką įmonėms, kurios sudaro kontroliuojamus sandorius, bei sandorių tarp asocijuotų asmenų kainodaros įvertinimo bei kontrolės metodiką mokesčių administratoriams. Iš šių dviejų metodikų buvo sudarytas sandorių tarp asocijuotų asmenų modelis bei pateikiami šio modelio taikymo pavyzdžiai. Disertacijoje pateikiama dažniausiai praktikoje pasitaikančių sandorių (prekių pardavimo, paslaugų teikimo, paskolų suteikimo, nematerialiojo turto perleidimo) kainodaros nustatymo pavyzdžiai Lietuvos įmonėms, o taip pat: disertacijoje buvo atliktas kontroliuojamų sandorių kainodaros reguliavimo efektyvumo Lietuvoje tyrimas.

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Loots, Jozua Johannes. "A comparability adjustment transfer pricing model / Jozua Johannes Loots." Thesis, North-West University, 2006. http://hdl.handle.net/10394/4484.

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The birth of democracy in South Africa on 27 April 1994 brought about irrevocable change. Markets opened up, economic activity and trade accelerated resulting in the South African economy being catapulted into the global market. Globalisation became a reality. Globalisation comprises structural transformation that affects enterprises and countries giving rise to new relationships and interdependencies. Globalisation creates a multiplicity of linkages and interconnections amongst countries and societies that constitutes the present world economic system. The multiplicity of linkages and interconnections aligns the Multinational Enterprise (MNE) as it relates to an integrated production and market network spread over various geographic locations. Historically, South Africa had stringent exchange controls to limit capital flows. Since democratisation in 1994, South Africa introduced transfer pricing legislation to administer transfer prices of goods and services within an MNE. The goods and services transferred within an MNE are not geographically bound and do not necessarily reflect economic market conditions. Hence, the approach used in transfer pricing is to determine the arm's length consideration based on what a willing buyer and seller would do, the market price. To establish the arm's length consideration, comparative benchmarks are used. Comparability, in this context, give effect to "what would have been if a willing buyer and seller" transacted. The concept of "what would have been", the comparative benchmark, could be ambiguous. Ambiguity is the result of the interpretation of "what would have been". In order to minimise ambiguity insofar as comparability, a comparability adjustment transfer pricing model (CATPM) is designed to recognise factors obtained from comparative benchmarks. The CATPM provides greater clarity insofar as the determination of the arm's length consideration. Clarity is achieved despite constraints such as unavailable South African comparable information with inconsistent use of foreign comparable data that results in ambiguous, subjective conclusions on the arm's length nature of transactions.
Thesis (Ph.D. (Business Management)--North-West University, Potchefstroom Campus, 2006.

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Mehafdi, Messaoud. "Behavioural aspects of transfer pricing in U.K. decentralised companies." Thesis, University of Greenwich, 1990. http://gala.gre.ac.uk/8713/.

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The central theme of this dissertation is the organisational and behavioural dimension of the transfer pricing problem as part of the management control process in the large decentralised company. The study examines the origin and developments of the problem through an extensive review of both the theoretical literature and a large number of previous empirical investigations. It is concluded from this literature review that the divergence between the theoretical prescriptions and practice stems from a conceptual and methodological deficiency as the problem has been repeatedly studied out of its context of decentralised managerial responsibility. Hence, the present study attempts to provide explanations as to why companies have particular transfer pricing policies by locating the problem in its context, that is the decentralised company. The organisational and behavioural approach adopted relates the transfer pricing system to the company's strategy, structure and culture through a multi-disciplinary analysis. The study draws on the literature on contingency theory, economics of the firm and agency theory to analyse the intricate relationships between the transfer pricing system, the company's structure and strategy and managerial behaviour. Great emphasis is placed on the managerial implications of transfer pricing through a questionnaire and interview survey of a sample of large divisionalised companies in the U.K.

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Kiluma, Stephen. "Transfer pricing in Tanzania: Regulating foreign investor's transparency obligations." Diss., University of Pretoria, 2017. http://hdl.handle.net/2263/64614.

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Kurasha, Primrose E. R. "Transfer pricing legislation in Zimbabwe : the need for reform." Diss., University of Pretoria, 2017. http://hdl.handle.net/2263/64617.

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Eich, Bettina. "Tax implications of transfer pricing on supply chain management." Master's thesis, University of Cape Town, 2011. http://hdl.handle.net/11427/10487.

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Includes bibliographical references (leaves 114-120).
Increased globalisation has lead to centralised risk management and decision-making in multinational enterprises, which gives rise to the principle of tax efficient supply chain management and the need to focus on the integration of tax considerations into the multinational's supply chain. In order to retain a competitive advantage in the global economy, multinational enterprises need to constantly search for cost benefits. This has created a market for tax motivated structures and the consequential action by tax authorities world-wide to regulate transfer pricing, in order to protect their respective tax bases. As revenue authorities increase their focus on transfer pricing compliance, it is vital that multinationals adhere to the arm's length principle and ensure their transfer pricing documentation can substantiate the transfer prices selected.

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Tocknell, Ingo. "Aggressive transfer pricing as a means to increase multinationals'competitiveness." Diss., University of Pretoria, 2017. http://hdl.handle.net/2263/59789.

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Aggressive transfer pricing is identified as a core competence that is required by multinationals to increase their competitiveness. The creation of a multinational is based on the evolution of corporate strategy, the culmination of which is encompassed by the internalisation theory. The main proponents of this theory is the efficient and effective management of internalised resources through the use of internal pricing. The purposes of this study was to establish if the possibility exists to use aggressive transfer pricing as a means to increase the competitiveness of multinationals. A deductive research approach was used to determine if the propositions set forth on the basis of the current literature would hold true when analysed based on data collected. A survey questionnaire was designed based on the literature review and submitted to respondents electronically. The results of the data analysis supported the propositions. The findings in this study enabled the researcher to deduce that the possibility indeed exists for aggressive transfer pricing to be used by multinationals as a means to increase their competitiveness.
Mini Dissertation (MBA)--University of Pretoria, 2017.
sn2017
Gordon Institute of Business Science (GIBS)
MBA
Unrestricted

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39

Elliott, Jamie. "Managing international transfer pricing policies a grounded theory study /." Thesis, Connect to e-thesis, 1999. http://theses.gla.ac.uk/634/.

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Thesis (Ph.D.) - University of Glasgow, 1999.
Ph.D. thesis submitted to the Faculty of Law and Financial Studies, Department of Accounting and Finance, University of Glasgow, 1999. Print version also available.

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Ritchie, Iain Fraser. "Funding liquidity risk and fund transfer pricing in banking." Thesis, Heriot-Watt University, 2016. http://hdl.handle.net/10399/3273.

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Funding liquidity risk was one of the main reasons for bank failure during the global financial crisis in 2007-2008. New legislation has been released in the form of Basel III, in particular the Liquidity Coverage Ratio (LCR) and the Net Stable Funding Ratio (NSFR), to strengthen the liquidity requirements for banks; this makes funding liquidity a very important topic for banks. In this thesis, I will study the important factors that need to be taken into consideration when dealing with liquidity risk and how a bank can manage their funding liquidity risk. A key concept used in banks is Fund Transfer Pricing (FTP). This approach helps the banks to manage their interest rate risk. I will investigate how funding liquidity risk can be incorporated into this framework. It is important that this approach will still maximise the bank's overall profits. In order to achieve this I will initially evaluate a one time period model. This shows whether the bank's overall profits can be optimised using FTP. My results show that it is possible to allow each business unit to work independently and that, by using FTP, individual business units can be optimised consistently with the bank's overall profits. However, for this to occur, it is important to decide whether a bank is deposit rich or deposit poor as an incorrect assumption will lead to sub-optimal profits for the bank. Banks work in more than 1 time period; therefore, I will assess how the model can be extended and how FTP would work over multiple time periods. One major consideration is to account for the uncertainty regarding the timing of cash flows. This is because customers often have the option to prepay loans or withdraw their deposits. I will investigate an approach for calculating the cost of these options and how this can be included in the FTP framework. By applying a cost to the uncertainty, we can insure that the business units are incentivised in the correct way while still maximising the profits of the bank. Under my approach the treasury unit will be exposed to actual events in return for receiving a fair value for the cost of the option. The business units will be charged the cost of the option. There is potential for one party to act in their own interest by changing the value of the option. However, as both parties need to agree, this risk should be removed over time. I have shown how this can be done over 2 time periods but further research is needed to investigate over more time periods.

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Rigon, Anna Paola <1989&gt. "Transfer pricing: i risvolti della disciplina internazionale sull'ordinamento interno." Master's Degree Thesis, Università Ca' Foscari Venezia, 2014. http://hdl.handle.net/10579/5371.

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Con la liberalizzazione dei mercati e la successiva internazionalizzazione delle attività, si è osservato un forte aumento delle operazioni commerciali transnazionali, intercorrenti anche tra imprese facenti capo ad un medesimo soggetto economico, ovvero il gruppo multinazionale. Tra le politiche che caratterizzano quest’ultimo, la determinazione del prezzo di trasferimento, cd. transfer pricing, è l’oggetto di analisi delle transazioni concluse tra le rispettive unità componenti. In un’ottica di ottimizzazione del risultato globale, è possibile rilevare l’alterazione dei corrispettivi suindicati, poiché pattuiti a condizioni differenti da quelle che contraddistinguono soggetti indipendenti svincolati da rapporti commerciali o finanziari, facendo sì che questi non siano conformi al principio di libera concorrenza o Arm’s Length Principle. Esso rappresenta la garanzia per un trattamento fiscale paritario tra le imprese associate e quelle che operano indipendentemente sul libero mercato, in quanto il prezzo di trasferimento può essere concepito come strumento volto allo spostamento di ricchezza, intesa come minor costo o maggior ricavo in capo al soggetto controparte, attribuendo così al transfer pricing i caratteri di fenomeno elusivo. Al fine di contrastare tale eventualità, si riscontrano molteplici interventi da parte di organizzazioni internazionali, finalizzati ad eliminare le alterazioni in esame mediante l’introduzione di metodi per la quantificazione del prezzo di trasferimento che riproduca il principio di libera concorrenza. Dato il carattere sovranazionale della disciplina, ciascuno Stato è invitato a recepire nel proprio ordinamento giuridico-tributario quanto concordato dalle citate organizzazioni in merito al transfer pricing, con particolare attenzione ai criteri per la determinazione dei prezzi di trasferimento, alla rispettiva documentazione che il contribuente deve fornire all'Amministrazione finanziaria e alla regolamentazione delle linee guida dirette alle autorità fiscali.

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Favaro, Francesca <1996&gt. "The impact of BEPS on Transfer Pricing of Intangibles." Master's Degree Thesis, Università Ca' Foscari Venezia, 2021. http://hdl.handle.net/10579/20478.

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In the current economic scenario, where globalization plays a relevant role, multinational groups tend to exploit all the chances given by the market in order to maximize their profits, through tax evasion, tax incentives, double non-taxation phenomena. When multinationals put in place transactions between associated enterprises, a transfer price is established for the transfer of goods, intangibles or the provision of services. An instrument that can be used by these groups so as to reduce taxation consists in manipulating the transfer prices by shifting profits towards lower taxation countries. This phenomenon represents the so-called transfer pricing. In order to counteract such phenomenon, the OECD (Organization for Economic Cooperation and Development) has developed a principle able to identify the transfer price between associated parties, the arm’s length principle, which considers the companies of a group as they would be independent enterprises. Nowadays, the transfer pricing phenomenon is even more challenging because of the involvement of intangibles in infra-group transactions. The increasing emergence of these difficult to evaluate assets has led to the development of aggressive tax planning schemes that created the BEPS phenomenon (Base Erosion and Profit Shifting). In order to prevent the mentioned schemes, the OECD created the BEPS Project (the Action Plan BEPS), which provides Actions 8 to address the evaluation of intangibles in the transfer pricing context.

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Lenik, Jean-Sébastien. "Prix de transfert & accords de repartition des couts (ARC)." Thesis, McGill University, 1999. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=30314.

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This thesis examines the transfer pricing issue within the perspective of setting up a cost contribution arrangement for the international management of intangible property.
To this end, the first part presents the general rules governing the transfer pricing area in Australia, Canada, France, and the United States. The provisions of these countries will serve as a guiding line of this study. The first part presents, as well, the OECD Transfer Pricing Principles.
The second part examines the structural alternatives of the CCA tax vehicle.
The third part addresses the CCA concept itself.
The fourth part deals with the operational functioning of a CCA. The new challenges and the multiple issues raised by this new tax structure are addressed as well as the tax planning perspectives opening up through transfer pricing.
Finally, the fifth part questions the new dynamics of the conflicts between tax administrations generated by the CCA vehicle.

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44

Riesbeck, Marcel. "Internprissättning : Två perspektiv på "rätt pris" utifrån armlängdsprincipen." Thesis, Högskolan i Skövde, Institutionen för handel och företagande, 2014. http://urn.kb.se/resolve?urn=urn:nbn:se:his:diva-9658.

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Internprissättning är vanligt inom dagens koncerner och växer mer allt eftersom världshandeln har globaliserats. Användandet av internprissättning för att öka vinsten är en diskussion som tog fart redan på 1950-talet. En diskussion som baserats på att bolag medvetet förbättrar sin skatt genom de olika metoderna som finns. Ett utnyttjande av regleringars brister och otydliga tolkningar. Ämnet är speciellt då det kräver kunskap inom både företagsekonomi och juridik. Att ämnet är brett gör det än mer komplext och en bredare kunskap krävs för att fullt förstå dess problematik.
Transfer pricing is common in today's corporations and grows more as world trade has become globalized. The use of transfer pricing to increase profits is a discussion that took off in the 1950's. A discussion based on the company consciously improve their taxes through the various methods available. A utilization of regulation flaws and unclear interpretations. The topic is unique because it requires expertise in both business administration and law. That the subject is wide makes it even more complex and broader knowledge required to fully understand its problems.

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45

Siddle, Robert. "Transfer pricing and intangible assets: problem areas in addressing the transfer of intangible assets." Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/18614.

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In assessing the problems that arise when the practice of transfer pricing is applied to the transfer of intangible asset transfers there are certain areas and nuances that need to be recognized. These include the distinction between economic and legal ownership and the fact that the two concepts, in certain circumstance, are mutually exclusive. Furthermore, the fact that the traditional methods of transfer pricing may not be able to address the unique nature of certain intangibles and that even the more complex methods involving both parties may fall short in situations where the rights and obligations connected to the intangibles assets are not subject to written agreements or accounting standards and procedures. In delving into the interaction of these two fields I will first establish the playing field and the rules, being the practice of transfer pricing, both on the international stage and domestic level. Next it will be necessary to understand the nature of intangible assets as viewed internationally. Upon reviewing the status of intangible assets in the context of transfer pricing I hope to locate the shortcomings caused by the unique characteristic of intangibles and hopefully will be able to suggest some viable options and alternatives.

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46

Suhr, Petronella. "The Revised Chapters I-III of the OECD Transfer Pricing Guidelines : A Comparative Analysis of the Changes and the US Transfer Pricing Regulations." Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Rättsvetenskap, 2010. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-14554.

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Russi, Kevin. "Kritische Analyse der Verwendung der Berry Ratio beim Transfer Pricing." St. Gallen, 2008. http://www.biblio.unisg.ch/org/biblio/edoc.nsf/wwwDisplayIdentifier/02601771002/$FILE/02601771002.pdf.

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Chang, Tang-Wen, and 唐文章. "The effect between transfer pricing and Organizational IdentificationThe effect between transfer pricing and Organizational IdentificationThe effect between transfer pricing and Organizational IdentificationThe effect between transfer pricing and Or." Thesis, 2008. http://ndltd.ncl.edu.tw/handle/92581832998253716445.

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碩士
中國文化大學
國際企業管理研究所碩士在職專班
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In recent years, economic development is flourishing, the industrial and commercial com-petition is becoming fiercer, the scope of the enterprise is scale new heights then before, it is me-ticulous that every department divides the work. The transfer of several labor service products is more frequent between every department. In traditional enterprises, it valuated that the interde-partmental transfer pricing by Market-based Pricing, the advantage of the law is being direct, saves time, especially the products that numerous items and the multi-storey transferred, it is very convenient to calculate. But in the organization of fraction type, department's executive has policy-making powers to the department activity, must be responsible for department's per-formance, the transfer prices influence the performance of the department. Every valuate way hard to understand and complicated and improper pricing way choose and the collocate meas-ures that system need (For instance: Man-hour report system) Will influence the each interde-partmental emotion or even the Organizational Identification . We research this to probe into different transfer pricing system to which kind of influence of aspect.

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Duen, Li Lou, and 段立如. "Multionationals and Transfer pricing." Thesis, 1993. http://ndltd.ncl.edu.tw/handle/05744754786155508156.

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Solilová, Veronika. "Transfer pricing nadnárodních společností." Doctoral thesis, 2010. http://www.nusl.cz/ntk/nusl-249249.

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Abstract:

International tax issues already have not been problems of narrow circle of multinational enterprises. The effect of globalization and international business development causes that many small and medium size firms are now engaged in cross-border transactions and have to face international tax issues. One of the important area of international taxes is transfer pricing. Transfer price is a price set by a taxpayer when selling to, buying from, or sharing resources with a related (associated) person. The transactions between these persons should be assessed at their arm's length price in according the arm's length principle (internationally accepted standard) as the price which would have been agreed between unrelated parties in free market conditions. This thesis focuses on the issue of the transfer pricing that multinational enterprises use to move their tax base to the countries with lower or no tax. The aim of this thesis is based on the analysis of transfer pricing regulations in individual EU member states to propose a new approach or any recommendations for the czech tax policy in the field of transfer pricing. In addition the gained practical knowledge applied to selected case studies.

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Dissertations / Theses on the topic 'Transfer pricing'

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