This paper is about the impact of risks on the controlled transactions procedures. The thing is that the controlled transactions are made by international companies to avoid high tax rates, but at the same time these companies have to face the international commercial risks. Therefore, the...

In this paper is analyzed the case of the coordination between tangibles and intangibles. Moreover, scrutinized the issue of the arm's length principle with one new view, which is the fixed length principle. This established principle shows a way to face the tax losses from a global economic...

This paper is about the tangibles and the intangibles of the controlled transactions. Therefore we have an analysis of the tangibles which are the property with the services, and the intangibles which are the assets of the controlled transactions in the transfer pricing procedure. Therefrom,...

This paper is about the controlled transactions in the case of intangibles. The intangibles have characteristics which are similar with than of tangibles. Through transfer pricing we have rights which granted from some companies to other, to achieve the appropriate profits and to minimize the...