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This analysis refers to the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. APAs are a type of non-bureaucratic, cooperative governance that exists between the multinational corporate taxpayer and the...
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as whole. However, because a single company can now have operations literally around the world, transfer pricing has …
Persistent link: https://www.econbiz.de/10014162143
, and still is, the creation of an exclusionary architecture that deprives the majority of the world's countries from … League of Nations and the OECD. Rejecting old and new solutions for a just world tax order, what the author believes is … actually needed is a completely different approach, grounded on contested multilateral practices and diversity of world views …
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The integration of world capital markets carries important implications for the design and impact of tax policies. This … theory. To the extent that multinational firms possess intangible capital on which they earn returns with foreign direct …
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One of the aims of the BEPS Action Plan is to reduce existing leeway for multinational enterprises to shift profits by exploiting transfer pricing rules. Profit allocation is meant to be aligned with “real activity” and “value creation.” This article is devoted to the question of whether...
Persistent link: https://www.econbiz.de/10013015843
This article considers multinational enterprises' capacity to deduct interest expenses in light of the implementation of Action 4 of the OECD/G20 Base Erosion and Profit Shifting Project and the OECD's current work on transfer pricing of financial transactions. It concludes that there has been a...
Persistent link: https://www.econbiz.de/10012862264
In order to create complex business structures and to obtain economic benefits, multinational companies have given rise to transfer pricing. Due to their importance, it has been possible to expand international trade to a higher level. This study focuses on the issue of transfer pricing and...
Persistent link: https://www.econbiz.de/10013502207