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This book contains essays written in honour of Prof. Dr Bertil Wiman, a renowned tax scholar and much-appreciated teacher. Wiman is one of the founding members of EATLP, former chairman of EATLP and former vice president of IFA. The essays cover various topics in the field of international tax...
Persistent link: https://www.econbiz.de/10012053371
Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative...
Persistent link: https://www.econbiz.de/10012112121
unilateral profit splitting and is suggested by the application of Shapley value theory to the fair and equitable division of …
Persistent link: https://www.econbiz.de/10012595108
Persistent link: https://www.econbiz.de/10001487105
The present paper studies among other issues the effects on equity and efficiency of two classic principles of international capital taxation: the principle of residence and the principle of source. In addition, it discusses harmonization and tax competition policies in corporate taxation,...
Persistent link: https://www.econbiz.de/10010508266
Der vorliegende Aufsatz untersucht unter anderem die Effekte zweier klassischer Prinzipien der internationalen Kapitalbesteuerung auf die Gerechtigkeit und die Effizienz: das Bestimmungslandund das Ursprungslandprinzip. Weiterhin werden die Harmonisierungs- und die Steuerwettbewerbspolitik in...
Persistent link: https://www.econbiz.de/10001381528
The goals of transfer pricing are to assign a monetary value to a transfer and to minimize the taxes paid by a company as whole. However, because a single company can now have operations literally around the world, transfer pricing has become a very complicated, costly, and lucrative business...
Persistent link: https://www.econbiz.de/10014162143
This paper studies the multinational firm's choice of transfer prices when the firm uses separate transfer prices for tax and managerial incentive purposes, and when there is penalty for noncompliance with the arm's length principle. The optimal incentive transfer price is shown to be the...
Persistent link: https://www.econbiz.de/10014069320
This paper studies two distinct roles that transfer prices play within multinational enterprises operating in two tax jurisdictions. Assuming that the multinational enterprise chooses one transfer price for tax purpose and another for providing incentives to its subsidiary's manager, we analyze...
Persistent link: https://www.econbiz.de/10014072538
This paper studies two distinct roles that transfer prices play within multinational enterprises operating in two tax jurisdictions. Assuming that the multinational enterprise chooses one transfer price for tax purpose and another for providing incentives to its subsidiary's manager, we analyze...
Persistent link: https://www.econbiz.de/10014067181