Littérature scientifique sur le sujet « Value creation. Transfer pricing. Intangibles »
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Articles de revues sur le sujet "Value creation. Transfer pricing. Intangibles"
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Hickman, Andrew. « The Application of Revised Transfer Pricing Rules to Aspects of Business Models ». Intertax 44, Issue 10 (1 octobre 2016) : 730–34. http://dx.doi.org/10.54648/taxi2016061.
Texte intégralRésumé :
The author discusses specific concerns about the efficacy of the application of transfer pricing rules to aspects of business models that have been addressed in the revisions to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines contained in the 2015 base erosion and profit shifting (BEPS) Report, Aligning Transfer Pricing with Value Creation. Distinctions are made between business models and transfer pricing business models that risk constraining the business to convenient explanations. Transfer pricing business models involving transfer of contractual risk and of legal ownership of intangibles are examined. Finally, the author predicts interest in single entity cross-border business models and the need to develop consistent guidance on attribution of profits to permanent establishments.
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Markey, Bram, et Isabel Verlinden. « From Compliance to the C-Suite : Value Creation Analysed Through the Transfer Pricing Lens ». Intertax 44, Issue 10 (1 octobre 2016) : 774–85. http://dx.doi.org/10.54648/taxi2016069.
Texte intégralRésumé :
Business models in a global context have evolved at a much speedier pace than the international tax framework. The internet of things, powerful corporate identities, innovative ways to play the market and an increasing reliance on intangibles are vital elements that lead to unprecedented ways of ‘value creation’. The Base Erosion & Profit Shifting (BEPS) project by the Organisation for Economic Co-operation and Development (OECD)/ Group of Twenty (G20) aims at ensuring that profits are effectively taxed where the economic activities generating the profits are performed. This is embedded in the premise that transfer pricing outcomes should be aligned with value creation. Many tax authorities and tax practitioners grapple with interpreting and translating value creation under innovative business models of multinational enterprises (MNEs) to the transfer pricing dictionary. In this article, the authors describe by means of examples how successful companies nowadays create value and unlock ‘economic rent’ across the value chain based on distinctive capabilities and unique business models. The authors subsequently put forward a novel economic approach to grasp value creation from a tax perspective in order to test whether there is a match with the transfer pricing outcomes. They started from the insights shared in ‘Strategy that works’ from PwC Strategy&, a playbook for the C-Suite to close the ‘strategy-to-execution’ gap.
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Dewi Astuti, Melani. « Country Note : Implementation of BEPS Recommendations in Indonesia’s New APA and Transfer Pricing Rules ». Intertax 48, Issue 12 (1 novembre 2020) : 1145–54. http://dx.doi.org/10.54648/taxi2020114.
Texte intégralRésumé :
Indonesia has recently updated its Advance Pricing Agreement and transfer pricing regulations in order to capture the development in the business and transfer pricing. It is also aimed to align with the Base Erosion and Profit Shifting (BEPS) recommendations. The new regulation has made substantial changes to the old advance pricing agreements (APAs) and transfer pricing regulations. With regards to transfer pricing, the new regulation has made some changes pursuant to the related parties’ definition, transfer pricing methods, comparability analysis procedures, special transactions, and intangibles. The transfer pricing guidance also provides guidance on the financial transactions and introduces the value creation concept. The new definition of related party is broader by providing more example on the ownership based on control. The regulation also allows the use of other transfer pricing methods other than the five OECD methods. Moreover, the intangible provisions have been modified to reflect the changes in the OECD Transfer Pricing Guideline 2017, to cover development, enhancement, maintenance, protection, and exploitation (DEMPE) activities and the economic owner. The guidance on financial transaction could also be useful for taxpayers and tax administration. Meanwhile, in terms of APA, the new regulation has provided a longer period of APA implementation, included a roll-back provision and modified the requirements regarding the submission of APA. Based on the new APA regulation, to submit an APA, a taxpayer cannot propose a lower profit than profit reported in the tax return. In general, the new regulation is in line with the BEPS 8-10 recommendations, albeit some differences are found, those are considered minor. The new regulations are expected to provide more certainty and simplicity for the taxpayers. Transfer pricing, APAs, Indonesia, advance pricing agreement, transfer pricing guidance, roll-back, related party, affiliated, transfer pricing methods, comparables
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Solange Screpante, Mirna. « The Arm’s Length Principle Evolves Towards a ‘Value Creation Functional (i.e. DEMPE) Formula Standard’ : A Barrier or a Gateway to Locational Business Planning ? » Intertax 48, Issue 10 (1 septembre 2020) : 861–78. http://dx.doi.org/10.54648/taxi2020087.
Texte intégralRésumé :
Value creation vis-à-vis the DEMPE rationale and methodology converted a conceptual notion associated with contributions to value creation but lacking prescription into a new standard to allocate profits to achieve reunification for tax purposes in a manner consistent with the directions of the arm’s length principle (ALP). Within this context, this article questions whether value creation could or should be based on a functional (i.e. DEMPE)-formula-based standard to allocate profits, and whether such an approach would target or abet tax avoidance framed by apparently genuine structures –‘accurately delineated’ (i.e. alignment of the allocation of profits with value-generating activities) that, in terms of how income is earned, might not be commercially rational. That said tax avoidance one that goes beyond the customary understanding and limitations of abuse under domestic law norms which paradoxically could make tax planning considered "abusive" easier to sustain within the BEPS precepts. Thus, the functional (i.e. DEMPE)-formula-based standard coupled with the commercial rationality test needs to be interpreted in a way that determines whether the performance of those functions by each party in a specific jurisdiction is rational from a commercial/business purpose perspective based on certain business parameters to provide taxpayers with a higher level of certainty, and in turn to devise suitable objective standards concerning the meaning of rationality in business operations for which typically there are open variuos legally sustainable ways to achieve the same economic outcomes. Value creation, intangibles, Actions 8–10, transfer pricing, source, commercial rationality, substance, anti-avoidance, arm´s length principle, fractional.
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Halyna, UMANTSIV, et SHUSHAKOVA Iryna. « CONTROLLED TRANSACTIONS WITH INTANGIBLE ASSETS IN THE CONTEXT OF THE BEPS ACTION PLAN ». Herald of Kyiv National University of Trade and Economics 135, no 1 (24 février 2021) : 101–18. http://dx.doi.org/10.31617/visnik.knute.2021(135)08.
Texte intégralRésumé :
Background. The Organization for Economic Co-operation and Development has launched a number of initiatives to solve global tax problem, since there are inconsistencies and gaps in the international tax legislation. The BEPS Plan is the most significant of these initiatives. Analysis of recent researches and publications. The review of scientific articles and publications revealed the relevance of the study of the analysis of the conditions of operations controllability with intangible assets and the choice of transfer pricing method through the identification of potential signs of comparability. The aim of the article is to study the approaches to the transfer pricing of intangible assets in the BEPS context in accordance with the concept of their implementation of the "outstretched hand" principle. Materials and methods. Different methods of scientific knowledge such as analysis, synthesis, deduction and induction, as well as methods of comparison, generalization and systematization have been used in the article. Results. Modern tendencies of development of the sphere of intellectual property have been analyzed. The globalization dimension of the processes of intellectual property formation has been studied and the place of Ukraine in these processes is revealed. The main trends of foreign economic transactions with intangible assets are identified. Business transactions with intangible assets for the purposes of transfer pricing are specified. The main measures for the implementation of the BEPS Action Plan in Ukraine are presented. Conclusion. It is identified that the results of comparability of the conditions of the controlled operation, the parties to the controlled operations with intangible assets should receive compensation based on the value they create through the performed functions, used assets and risks assumed in the development process, strengthening, maintenance, protection and use of such assets. This necessitates the formation of approaches to the tax administration of transfer prices, which will ensure the creation of competitive economic relations, the introduction of clear and transparent mechanisms for determining contract prices. Keywords: transfer pricing, related parties, controlled transactions, BEPS, intangible assets, royalties, international trade in services.
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Konina, N. Y. « MAJOR TRENDS OF BIG INTERNATIONAL COMPANIES DEVELOPMENT IN A CHANGING WORLD ». MGIMO Review of International Relations, no 1(46) (28 février 2016) : 143–53. http://dx.doi.org/10.24833/2071-8160-2016-1-46-143-153.
Texte intégralRésumé :
Economic globalization and demographic changes as well rapidly changing technologies are the most important factors of the firm's environment. The rapid development of information technology radically changes the very essence of the creation of new value. The pace of technological change and innovations increases. In the most advanced sectors of global economy the knowledge is a key resource. The world economy has not finally recovered after the crisis of 2008-2009. The global economy his becoming more multicentre and the vector of economic power is shifting to China and India. The main actors and the anchor of today global economy are leading international companies (transnational corporations- TNCs). Several thousands of TNCs together with their value chain dominate the global economy. The economic power allows the largest TNCs significantly push the boundaries of the company. Globalization has changed external networks of TNCs, their corporate governance, corporate ownership as well transfer pricing schemes as well relations between the headquarter and its subsidiaries and affiliates. A remarkable feature of TNCs recent FDI flows is not Greenfield investment but mergers and acquisitions. Key features of TNC activities are defined by industry. A growing number of TNCs are changing their strategic activities, basing on the latest technology trends. The most important aspects of TNCs activities are linked to innovation, financial operations, advanced management technique, increase in intangible assets. Innovation activity of TNCs is shifting to Asia.
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Aniyie, Ifeanyichukwu Azuka, et Osamuyimen Enabulele. « Nigeria's Income Tax (Transfer Pricing) Regulations 2018 : Conceptualizing the Elephant and “Plucking the Goose” ». Journal of African Law 64, no 2 (15 mai 2020) : 267–86. http://dx.doi.org/10.1017/s0021855320000108.
Texte intégralRésumé :
AbstractIn 2015, the OECD gave the world a template to address base erosion and profit shifting and ensure that profit is taxed in the jurisdiction of value addition and / or where economic activities take place. The world's jurisdictions then embarked on implementing the template. Examining the legal framework subsequently put in place for the taxation of intangibles in Nigeria, this article argues that the distinct regimes for connected and unconnected persons’ transactions create flaws. It further asserts that these flaws are consequences of the conflict between the policy that underpins the legal framework and other policies in the country. It concludes that the legal framework may not be a “Swiss army knife” (providing Nigeria with all that is needed to combat transfer pricing issues associated with the transfer of intangibles by connected persons), as it creates issues that have undesired consequences for the taxation as well as the economic system.
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Seppälä, Timo, Martin Kenney et Jyrki Ali-Yrkkö. « Global supply chains and transfer pricing ». Supply Chain Management : An International Journal 19, no 4 (3 juin 2014) : 445–54. http://dx.doi.org/10.1108/scm-01-2014-0049.
Texte intégralRésumé :
Purpose – The purpose of this paper is to integrate the issue of transfer pricing and logistics costs to understand trade statistics and the operation of supply chains by using invoice-level data for a single globally sourced product of a multinational firm.Supply chains are central to understanding wealth creation and capture in an increasingly globalized production system. The increasing disaggregation and dispersal of supply chains is profoundly affecting the geographical distribution of value added, input costs and profits of multinational firms. This suggests that understanding supply chains and where the activities and accounting for these activities take place is crucial for understanding the causes and consequences of contemporary globalization. Design/methodology/approach – By using a case study of a single product and invoice-level data, it was possible to capture the actual costs incurred by a firm using a relatively simple global supply chain. The authors show how corporate intra-firm transfer pricing determines which business unit and location captures profits. A single firm provided the core data in this paper, including product- and firm-level information on intermediate product prices and input costs for all internal transfers. Findings – This paper advances interesting insights into trade in value added and shows that, though not often considered significant, transfer pricing is a critical issue for understanding the geographical distribution of value added. The authors conclude with some observations about the nature of global supply chains, the value of international trade statistics and a hidden advantage of an integrated firm operating on a global scale the ability to somewhat arbitrarily select the activities to which profits should be allocated. For nation states, as supply chains become more international and complex, critical measures, such as gross domestic product, worker productivity, etc., are becoming ever more imprecise. The economic geography of cost of inputs and profits continue to separate as multinational enterprises drive the disaggregation of value creation and value capture. Research limitations/implications – The case study facilitates an understanding of complex supply chain issues, thereby extending and deepening findings from previous research. This case study of transfer pricing in supply chains will assist other scholars in better formulating testable propositions for their studies and sensitize them to the internal complexities corporate managers face when making operationalizing decisions. Originality/value – The case study suggests that understanding the configuration of and accounting in supply chains is vital for accurately measuring any national economic statistics. This case study provides some bottom-up evidence that national accounts and international trade economics undertaken without a deep understanding of supply chain organization is likely to generate misleading results. The methodology of using invoice-level data can provide a more granular understanding of how supply chains are organized and where the value is added and captured. For practitioners, the data suggest that firms should think very carefully about which of their activities generate the most value, and value those accordingly.
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Brem, Markus, et Thomas Tucha. « Transfer Pricing : Conceptual Thoughts on the Nature of the Multinational Firm ». Vikalpa : The Journal for Decision Makers 31, no 2 (avril 2006) : 29–44. http://dx.doi.org/10.1177/0256090920060202.
Texte intégralRésumé :
This paper deploys Transaction Cost Economics (TCE) to elaborate on the shortcomings of ‘mainstream‘ transfer pricing in multinational firms. Departing from the notion that multinationals increasingly (re-)organize their business along multinational value chains irrespective of jurisdictional borders, this paper discusses the nature of the multinational firm and the problem of choosing the right intra-group (transfer) price. The mainstream transfer pricing approach derived from the Arm�s Length Principle (ALP) is deemed inappropriate for globally operating multinational enterprises (MNEs). Referring to the value chain model, the paper suggests that ‘entrepreneurial coordination’ is the key performance feature to be used for valuing business activity and for allocating — for tax transfer pricing purposes — standard mark-ups and residual profits along the value chain. The main findings of this paper are: Neo-classical concepts on marginal pricing may not suffice to establish arm's lengh transfer pricing; the inadequacy between tax-world transfer pricing (getting income allocation right) and business-world transfer pricing (getting management incentives right) might find its explanation in such concepts. MNEs need to be understood as large organizations different from domestic large organizations by the fact that they operate in different jurisdictions and/or institutional environments. Operative business is coordinated along business lines in which value chain processes can e identified. De facto, business-world transfer pricing takes place along such value chains in which tangible and intangible assets are transferred and hence require appropriate pricing from both the tax-world and the business-world perspective. TCE is a worthy candidate for illustrating governance structures and transactional attributes of business between related parties of a multinational group; such features support arguments to establish arm's length transfer pricing. Regularly, a clear cut-off of functional allocation into tax jurisdictions is difficult to achieve because of the high degree of integration into the value chains of the multinational. TCE appears to better distinguish between so-called �routine� and ‘non-routine’ functions. Transactions of the MNE are rarely of an ‘either-or’ feature (either ‘market’ or ‘hierarchy’). Depending upon transactional attributes, the price of such transaction can be assessed by variables describing the institutional and economic context, the transaction-specific contract, the stage of the business process involved, the strategy chosen, and the function pattern (function, risk, assets) Comparable information is rarely found in databases which provide company information. The more non-routine functions and intangibles are involved, the less is the tested function (or business unit) comparable with companies from external databases. Under these data constraints on comparables, the arm�s length tests on transfer pricing will have to resort to internal information if the ALP is intended to remain viable. A next-generation transfer pricing approach may have to make use of patterns of governance to characterize and to value the functional contributions to the overall value chain.
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Хаванова, Инна, et Inna Khavanova. « Category of Market Price in Modern Tax Law ». Journal of Russian Law 4, no 7 (5 juillet 2016) : 0. http://dx.doi.org/10.12737/20152.
Texte intégralRésumé :
The article is devoted to transfer pricing rules with particular reference to unresolved problems. Its purpose is to outline the complex issue of transfer pricing. The author examines the difference between the concepts of “market price” and price, determined according to the “arm’s length principle”, discusses the basic rules of taxation, principles of determining the price of goods, work or services for taxation purposes. To ensure the correct application of the separate entity approach, countries have adopted the arm´s length principle. This article analyzes initiatives on taxation in the area of corporate taxation (OECD Action Plan on Base Erosion and Profit Shifting (BEPS), Final Reports “Aligning Transfer Pricing Outcomes with Value Creation”). The author points out that the level of control (direct or indirect) in determining interdependence between persons, has its own specific features in different states. The reason behind it is that the problem of transfer pricing does not always arise, but only when subjects establish specific relations. The article characterizes the regulatory changes and developments in Russia.
Thèses sur le sujet "Value creation. Transfer pricing. Intangibles"
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Enrica, Core. « Value creation in the beps era and a new approach to transfer pricing for intangibles ». Doctoral thesis, Luiss Guido Carli, 2020. http://hdl.handle.net/11385/203560.
Texte intégralRésumé :
General principles of international tax law for the localization of cross-border income in the space. The localization of cross-border income according to the standard of “value creation” in a post-beps system. The application of “value creation” approach to transfer pricing. The digitalization of the economy and the “value creation” challenges. The rise of the digitalization of the economy and the international tax debate. Users and data as possible taxable connecting factors and the implications for the transfer pricing rules
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Claesson, Ida. « Business Restructuring : The applicability of the arm's length principle for intangibles with an uncertain value at the time of the restructuring ». Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Rättsvetenskap, 2012. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-19074.
Texte intégralRésumé :
This thesis is based on the regulations found in the OECD model and the OECD TP guidelines concerning the arm’s length principle. The core of the arm’s length principle is that transactions between associated enterprises should be treated the same as transactions between independent enterprises. This principle can be found in Article 9 of the OECD model. One transaction that may fall within the scope of Article 9 of the OECD model is business restructuring. Business restructuring was previously an unregulated TP area but with the new OECD TP guidelines, from 2010, regulations have been formulated. The aim with thesis is therefore to examine how the arm’s length principle should be applied to the new guidelines for business restructurings of intangibles with an uncertain value at the time of the restructuring. In order to answer the question set out in this thesis some of the factors that affect the application of the arm’s length principle have been examined separately. Firstly the arm’s length principle that is the generally accepted TP method used by both taxpayers and tax administrations in order to find a fair price for transactions between associated enterprises. The principle seeks to identify the controlled transaction and thereafter find a comparable uncontrolled transaction that is similar to the transaction performed between the associated enterprises. The second part examined the meaning of the term business restructuring according to the new guidelines since there is no other legal or general definition. Business restructurings are defined as cross-border redeployments of functions assets and risks, performed by MNEs. As long as a transaction falls within this definition it will be subjected to the arm’s length principle for tax purposes. The third part examined intangibles since that also lack a general definition. The identification and valuation of intangibles is a complex and uncertain thing to do for both taxpayers and tax administrations. When applying the arm’s length principle it is however found that the issue of identification of what constitutes and intangible may be unnecessary. The aspect that should be considered is instead the value of the intangible or more precise, the value that independent enterprises would have agreed upon in a similar situation. The applicability of the arm’s length principle to business restructurings of intangibles with an uncertain value at the time of the restructuring should be found by performing a comparability analysis. In order to perform a comparability analysis, the controlled transaction firstly has to be identified. Thereafter, a comparable uncontrolled transaction needs to be found. An equivalent uncontrolled transaction may not be found in all cases and it should in those cases be examined what independent enterprises would have done if they had been in a comparable situation. The arm’s length principle should be applied to business restructurings of intangibles with an uncertain value in the same manner as for any other uncontrolled transaction. The issues for this type of a transaction become the identification of what constitutes a business restructuring and also how to determine a fair value for the intangibles. The OECD TP guidelines lack some guidance as to the issues that can occur when a comparable uncontrolled transaction cannot be found. This creates an unsatisfactory guesswork for both taxpayers and tax administrations when trying to determine what independent enterprises would have done if they had been in a similar situation. This creates an unnecessary uncertainty when trying to apply the arm’s length principle.
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Siewe, Constantain Lendeu. « A comparative analysis of the effective use of transfer pricing policies in multinational manufacturing corporations in Southern Gauteng ». Thesis, 2016. http://hdl.handle.net/10352/344.
Texte intégralRésumé :
M. Tech. (Cost and Management Accounting), Vaal University of TechnologyThis study was undertaken to assess the extent to which transfer pricing was effectively used by multinational manufacturing companies operating in the Southern Gauteng region of South Africa. The target participants of the study traded their products across international borders and as such made use of transfer pricing in one way or the other to achieve strategic objectives. Scant research has been undertaken to analyse the degree to which transfer pricing can be used to effectively influence managerial performance. On the other hand there is a wealth of knowledge on the relationship between transfer pricing and taxation. In-depth review of literature showed that even though multinationals formulated their transfer pricing policies to target financial and managerial objectives, self-interest and outside influences tended to hinder the equitable realization of both types of objectives. The study therefore set out to establish whether this is true of Multinational corporations (MNCs) in Southern Gauteng and in the process answer questions about the procedure for formulating transfer pricing policies by these MNCs, the relationship, if any, between transfer pricing and profitability and the use of transfer pricing for performance enhancement and assessment. The study made use of a mixed methods research methodology to collect and analyze data from 45 MNCs operating in the target geographical area. Of the 45 companies, 15 cooperated fully with the study. Data was collected via the use of questionnaires and follow-up face-to-face and/or telephonic interviews. Collected data was analysed using statistical methods including the Chi Square Test, standard deviation, frequency tables and the Kruskal-Wallis H test. The results from the questionnaire and interviews show that there is no universally appropriate Transfer Pricing Policies(TPP) which applies equally to all organizations in all circumstances. Firms are affected by different environmental factors while striving for tax-compliance and value creation. The fear of falling on the wrong side of tax laws is a major driving force behind transfer pricing policies of MNCs. As such other objectives that are managerial in nature become secondary and tend to be neglected if/when they conflict with the primary objective.
Livres sur le sujet "Value creation. Transfer pricing. Intangibles"
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Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports. OECD, 2015. http://dx.doi.org/10.1787/9789264241244-en.
Texte intégralChapitres de livres sur le sujet "Value creation. Transfer pricing. Intangibles"
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Nagatkin, Anton, Roman Kral et Janine Stockmeier. « The Miracle of Brand Value Creation : Where Does the Value Come From ? » Dans Intangibles in the World of Transfer Pricing, 141–62. Cham : Springer International Publishing, 2021. http://dx.doi.org/10.1007/978-3-319-73332-6_8.
Texte intégral
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Heidecke, Björn. « Please Mind the Gap : Arm’s Length Prices and Fair Market Value ». Dans Intangibles in the World of Transfer Pricing, 263–72. Cham : Springer International Publishing, 2021. http://dx.doi.org/10.1007/978-3-319-73332-6_14.
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Vet, Cassandra, Danny Cassimon et Anne Van de Vijver. « Getting the Short End of the Stick : Power Relations and Their Distributive Outcomes for Lower-Income Countries in Transfer Pricing Governance ». Dans Taxation, International Cooperation and the 2030 Sustainable Development Agenda, 3–27. Cham : Springer International Publishing, 2021. http://dx.doi.org/10.1007/978-3-030-64857-2_1.
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AbstractIt is widely recognized that international corporate taxation holds a distributional bias toward advanced economies and that developing countries only play a marginal role in tax governance-making. Yet, it is the ambition of both the G20 and the Organisation for Economic Co-operation and Development (OECD) to integrate developing countries in the BEPS Inclusive Framework. The Base Erosion and Profit Shifting (BEPS) action is the latest global initiative to update the international framework of corporate taxation and curb corporate tax avoidance. On one hand, the integration for developing countries within the policy-making forums remains incomplete and focused on the implementation of the global tax rules. On the other, even when lower-income countries have a seat at the table, uneven power relations shape the distributional outcomes of the G20-OECD tax reform project. This analysis of the power relations at play during the revision of the transactional profit split method (TPSM) reveals how dominant logics on value creation work against the material interests of developing countries in the distribution of taxing rights. Therefore, for a tax reform to be truly legitimate for developing countries, it should emancipate and even “decolonize” the discourse and ideas of the international tax regime. While the updated OECD guidelines on transfer pricing expanded the size of the overall cake of taxable profits, the dominant logics and criteria of the guidance make it difficult for lower-income countries to obtain a decent slice of the cake and actually eat it.