Chapter of International Fiscal Association –Indian Branch Transfer Pricing Problems‚ Strategies and Documentation Recent International Case Law on Transfer Pricing by Nishith Desai The Taj Mahal Hotel‚ Mumbai January 21st & 22nd 2002 Nishith Desai Associates 2 TRANSFER PRICING Content I. II. Introduction History III. Select International cases US Cases 1. 2. 3. Compaq Computer Corporation V. Commissioner DHL Corporation and Subsidiaries V. Commissioner Texaco Inc. and Subsidiaries
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Transfer Pricing in Developing Countries An Introduction Topics 1. Abstract 2. International tax law & its sources 3. Brief history of International Tax Law 4. Who gets the pie? 5. Arm ’s length principle : Cornerstone of International Tax Law 6. Transfer pricing methods 7. Problems with of source taxation of MNE ’s 8. Internet & e-commerce : Achilles heel of current International taxation regime? 9. Formulary Apportionment (FA) 10. Existing uses of Formulary Apportionment systems in the world
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CASE STUDY: PEL’S APPLIANCES LEADS TO SUCCESS OVER THE TIME Pak Elektron Limited (PEL) is the pioneer manufacturer of electrical goods in Pakistan. It was established in 1956 in technical collaboration with M/s AEG of Germany. In October 1978‚ the company was taken over by Saigol Group of Companies.. Since its inception‚ the company has been working for the advancement and development of engineering know-how in Pakistan. The company has produced hundreds of engineers and skilled workers and
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General procedure for transfer of shares 1. The transferor and transferee are required to execute a share transfer form under their common seals (if they are corporations) in accordance with their respective Constitution/Articles of Association. 2. The transfer is subject to ad valorem duty payable to the Commissioner of Stamp Duties (“Commissioner”). The current stamp duty payable on the transfer of shares is 20 cents for every S$100/- or part thereof of the consideration for
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149 Control w it h fairness in transfer pricing A transfer price is useless unless unit managers feel they are being treated fairly while top management retains control Robert G. Eccles It seems straightforward on the face of it: when a unit in a company sells a product to another unit‚ it ought to charge a fair price. That price may be based on what it cost to make the product‚ or on the market price of the product‚ or on some combination of these two. But as most managers
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Transfer of learning is the study of the dependency of human conduct‚ learning‚ or performance on prior experience. The notion was originally introduced as transfer of practice by Edward Thorndike and Robert S. Woodworth. They explored how individuals would transfer learning in one context to another context that shared similar characteristics – or more formally how "improvement in one mental function" could influence another related one. Their theory implied that transfer of learning depends on
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2009 A REPORT ON TRANSFER PRICING – BENCHMARKING ANALYSIS PricewaterhouseCoopers Pvt Ltd By NAME Tax :- NEHA Services and RegulatoryAGARWAL (TRS) ENROLLMENT NO :- 08BS0001891 Transfer Pricing MOBILE NO :- 9830117116 Neha Agarwal 08BS0001891 //2009 Transfer Pricing study A REPORT ON TRANSFER PRICING – BENCHMARKING ANALYSIS By NAME: - NEHA AGARWAL ENROLLMENT NO:-08BS0001891 MOBILE NO:-+919830117116 A report submitted in partial fulfillment of the requirements of
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Topic TRANSFER PRICING TRANSFER PRICING is a term used to describe all aspects of inter Company pricing arrangements between related business entities‚ and commonly applies to inter Company transfers of tangible and intangible property. Inter Company transactions across borders are growing rapidly and are becoming much more complex. Transfer pricing refers to the internal pricing system that is used when divisions in the same firm deliver products or services to each other. The transfer price
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7 Transfer Pricing LEARNING OBJECTIVES : After studying this chapter students will understand. * Purpose of transfer pricing * Responsibility of a division as responsibility centre * Conflicts between the divisions * Setting of transfer price where the profit of the organisation can be higher. 7.1 Introduction The whole organisation can be divided into a number of divisions‚ the performance of each division can be measured in terms of both the income earned and the
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Lectures of Heat Transfer Heat Transfer Rate Processes Mode Conduction Convection Radiation Transfer Mechanism Diffusion of energy due to random molecular motion Diffusion of energy due to random molecular motion plus bulk motion Energy transfer by electromagnetic waves Rate of heat transfer (W) q = - kA dT dx q = h A(Ts-T∞) q = σ ε A(Ts4-Tsur4) By Mr. Amjed Ahmed Ali Syllabus of Heat Transfer (English)‚ (2 hours/ week‚ Applied 2 hours /week) 1.Heat transfer by conduction‚ convection
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