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argument, I will discuss decisions of different jurisdictions, including the United States, Canada, Germany and South Africa. …
Persistent link: https://www.econbiz.de/10009418466
This paper analyzes transfer pricing incentives under a destination-based and an origin-based VAT system. While a switch to the origin-based VAT may moderate or reinforce the incentive for transfer pricing induced by income tax differentials, we show that in the case of the EU this switch tends...
Persistent link: https://www.econbiz.de/10010986309
This report summarizes 39 detailed ETLA case studies of global value chains (GVCs). The findings suggest that the value added in global value chains is less tied to their tangible aspects than what conventional wisdom suggests. Intangible aspects of GVCs tend to be more important, but their poor...
Persistent link: https://www.econbiz.de/10010987097
The European Court of Justice has confirmed the compatibility of transfer pricing adjustments under the arm's length standard in its "SGI" judgment. In this decision, the ECJ has stated that transfer pricing control is justified as a means to fight "artificial arrangements" while commercially...
Persistent link: https://www.econbiz.de/10010990340
Transfer pricing is relevant in three different contexts: From a managerial perspective, intra-firm transfer prices are employed to set incentives for sub-divisional managers to enhance efficient allocation of resources. From an international tax perspective, transfer pricing rules under the...
Persistent link: https://www.econbiz.de/10010990354
Economic theory implies that research and development (R&D) efforts increase firm productivity and ultimately profits. In particular, R&D expenses lead to the development of intangible assets in the form of intellectual property (IP) and these assets command a return that increases overall...
Persistent link: https://www.econbiz.de/10010862574
We present a new model of tax induced transfer pricing as an alternative to the oft-used concealment model. Inspired by interviews with practitioners, we consider a large multinational firm which is audited by the tax authority in the high-tax location. When this country adjusts the transfer...
Persistent link: https://www.econbiz.de/10010877753
We present a new model of tax induced transfer pricing as an alternative to the oft-used concealment model. Inspired by interviews with practitioners, we consider a large multinational firm which is audited by the tax authority in the high-tax location. When this country adjusts the transfer...
Persistent link: https://www.econbiz.de/10010904678
The CAPM implies that investors require equity risk premia when choosing risky investments and therefore demand higher returns to equity invested if higher risk is present. This should apply to investments in independent enterprises and multi-national enterprises alike. This hypothesis is...
Persistent link: https://www.econbiz.de/10010941794
A long period of rig scarcity and high rates has led to innovation in the procurement of rig services and in relationships between oil companies and rig contractors. Discussions have been conducted on joint ventures between companies and contractors, for instance. This paper describes and...
Persistent link: https://www.econbiz.de/10010948865