International transfer pricing between Germany and China - wts.de
Dec 30, 2013 - Diagram 1: Transfer of a business function from a German perspective .... application of the time apportionment method [GuoShuiFa (2004) no.
Feb 21, 2014 - porting for all internationally active groups. In addition, it would be very helpful to provide the taxpayer with a standardized documentation ...
(Q1) âTransfer Pricing is not an accounting toolâ comment. .... If all of these conditions are present, a transfer price system based on market prices would induce goal ... Full information. PROBLEMS IN MARKET BASED TRANSFER. Most markets are not
Some well-known cases: Google, Apple, Starbucks, Pfizer often through ... Recent direct evidence (US, France, Denmark, and Germany):. Clausing (2003): ...
This paper presents new evidence on tax-motivated transfer mispricing in real goods by exploiting ... Our paper adds to the literature in four distinct ways. First ...... Panama. 1. 1. 1. Saint Kitts and Nevis. 1. 1. 1. Saint Lucia. 1. 1. 1. St. Mart
results should persist when allowing for some degree of competition across modes of exporting. 17While Cristea and Nguyen (2016) assume the penalty ...
Feb 21, 2014 - the OECD makes a strong statement in support of the opinion ... First comment box - preparation of master file on a line of business basis:.
Dec 2, 2015 - view of the global group), a local Australian transfer pricing file (that is ...... 42 of the Spanish Code of Commerce), and are not at the same time ...
Aug 14, 2013 - Engaged in providing software development services, Knowledge Process ... requirement is for the taxpayer / applicant company to bear 'insig-.
Aug 14, 2013 - Engaged in providing software development services, Knowledge Process Outsourcing ... services or information technology enabled service (ITeS), with ... requirement is for the taxpayer / applicant company to bear 'insig-.
Feb 17, 2015 - tax administration following the issuance of the first batch of BEPS ..... Generally, a master file documentation approach as proposed by the OECD is already ..... assessment, to the degree that they did not contain confidential ...
Feb 21, 2014 - Also a TP risk assessment or even audit on the basis of a CbC reporting does not seem possible in practice as the data to be included will not be representative nor comparable. (further outlined in section C.1.). However, we welcome th
Apr 10, 2014 - In the following, we would like to comment and assess the four provided possible actions and outline our .... follow a global formulary apportionment instead of being based on the arm's length prin- ciple. (23) The .... (30-32) As four
Feb 21, 2014 - could tremendously reduce compliance efforts whereas at the same ... Taxpayer's assessment of its compliance with the arm's length principle.
Journal of IntcmationaI Ecor~omics 24 (1988) 147-157. North-Holland. ENDOGENOUS TRANSFER PRICING AND THE EFFECTS OF. UNCERTAIN REGI.JLATION chander KANT*. Cbtblic University 4p America, W~hingtor~, DC ZUM4, USA. Received February 1986, revised versio
the charging of such services within a group. Moreover, authorities from various jurisdictions are increasingly active in developing and enforcing additional transfer pricing related regulations. Besides the activity of the JTPF with respect to Europ
Feb 17, 2015 - The businesses carried out by the companies. â The fiscal regime ... arrangements, low return to high-tech enterprises, etc. In December 2014 ...
Oct 2, 2016 - Poland: Update on the implementation of CbC Reporting in Poland . .... multinational enterprise group with consolidated revenue over. RMB 5.5 ...
Dec 2, 2015 - arrangements to avoid the attribution of business profits to Australia ... total accounting income, taxable income and income tax payable. ..... nizing that in the presence of proper business purposes, taxpayers should be free to choose
Dec 2, 2015 - changes in the legislation on transfer pricing from a local country ... Ukraine: The Variations in the List of Controlled Transactions in Ukraine. ... Information to be disclosed includes the entity's name and ...... 1227 Makati City.
Multinational. Enterprises and. Tax Administrations. 22 JULY 2010. Page 3 of 375. OECD Transfer Pricing Guidelines.pdf. OECD Transfer Pricing Guidelines.pdf.