Transfer Pricing
In taxation and accounting, transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length (the arm’s-length principle). The OECD and World Bank recommend intragroup pricing rules based on the arm’s-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative …
WikipediaPublications
The South Centre · 15 April 2024 Spanish
The Supreme Court found that in the absence in the Bill of mitigatory measures -as allowed by the TRIPS Agreement- and of a working definition of the term “microorganism”, there …
introduced in 2012 with the objective of reducing transfer pricing disputes and providing certainty to taxpayers … profitable MNEs, so that the existing rules on transfer pricing would continue to apply in all other cases … profitable MNEs, retaining the current defective transfer pricing rules for all other purposes. For Amount A … simplify transfer pricing rules for ‘baseline’ marketing and distribution functions. Transfer pricing remains … developing countries. The ultimate objective of transfer pricing is to determine a market price for intra-company …
14 April 2024
This study examines the prevalence of transfer pricing and earnings management activities, and how they are impacted by corporate governance mechanisms. Using the political cost theory, the study provides … from 16 listed firms for the period 2008-2020. The results reveal that the transaction-based transfer pricing model is better than the index-based model and the accrual-based earnings management model suits … Board size and female CEO increase transfer pricing aggressiveness but board independence, CEO tenure, CEO nationality and female Board Chairwomanship reduce transfer pricing aggressiveness. The findings also …
World Bank Group · 11 April 2024 English
Post 431,700 20 Database subscription for transfer pricing information 2 Goods RFB Post 440,000 21 License … 2022-06-01 SER-TAMP-DS-G-22-26 / Lice nse for Transfer Pricing Catal yst database IBRD / 89360 STA Organization …
ActionAid International · 10 April 2024 English
Despite these already low levels of spending on the public sector workforce, 20 countries have seen active declines in their spending on public sector workers as a % of GDP …
activities and an inability to fight abuses of transfer pricing by multinational enterprises; re-equilibrate …
UN DESA: United Nations Department of Economic and Social Affairs · 4 April 2024 Latin
In short, it reflects including developing countries not investing enough in tax the growing understanding among Member States about system reform and administration capacity, and donors the importance of building …
for measurement and is conducting abusive transfer pricing, trade misinvoicing and tax evasion.55 Member …
UN DESA: United Nations Department of Economic and Social Affairs · 4 April 2024 English
Financing for Sustainable Development Report 2024 Inter-agency Task Force on Financing for Development Financing for Development at a Crossroads Domestic Public Private Business Development Debt Trade Systemic Technology Resources and …
for measurement and is conducting abusive transfer pricing, trade misinvoicing and tax evasion.55 Member …
AEI: American Enterprise Institute for Public Policy Research · 25 March 2024 English
Key Points While the 2017 Tax Cuts and Jobs Act (TCJA) reformed the tax code to encourage growth and ease the tax burden on individuals and businesses, many of its …
profits to low-tax jurisdictions through transfer pricing or cross-border borrowing. This would simultaneously …
EU: European Union · 25 March 2024 English
accordance with the margin method of the OECD Transfer Pricing Guidelines, constitutes a payment for a service …
IISD: International Institute for Sustainable Development · 22 March 2024 English
Do policy-makers need to rethink fiscal policies to ensure the financial benefits from critical minerals are shared fairly?Are current fiscal approaches and policies aligned with national strategies, including ensuring that …
effect on government revenues; ⁰ a risk of transfer pricing abuse; and ⁰ artificially reduced taxable … determining the price of minerals using a transfer pricing framework, particularly for scenarios in … and royalties are calculated; • a risk of transfer pricing abuse—under-pricing specifically—if the mining …
World Bank Group · 22 March 2024 English
including Inte rnational Tax Cooperation on Transfer Pricing IDA / 62880 Strengthening Revenue Man agement …