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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MANAGING TRANSFER PRICING Sarbanes-Oxley requires a company to establish that it has internal controls to ensure accurate financial reporting and that the auditor attest to the assessment of those controls. An obvious concern for all multinationals after SOX is whether there are effective controls in place to deal with transfer pricing exposure. An increasingly important element of transfer pricing documentation relates to the influence of legislation‚ ethical standards‚ and associated matters
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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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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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The University of Sydney Aerospace‚ Mechanical and Mechatronic Engineering MECH3260 Thermal Engineering Heat Transfer Quiz 3 2007 Time: 40 minutes Answer ONE question only. Question 1 Consider the cylindrical receiver in a solar thermal power plant shown below. The receiver is made of opaque material and has a diameter D = 8m and length L = 14m. At a particular time‚ the heliostats direct a concentrated solar flux of q”S = 80 kW/m2
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Western Regional 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
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THE TRANSFER OF PROPERTY ACT‚ 1882 PERSONS COMPETENT TO TRANSFER (Section-7 ) Submitted by: Ananya mohapatra BBA-LLB (A) 5th Semester 1082015 PERSONS COMPETENT TO TRANSFER (Section-7) Every person competent to contract and entitled to transferable property‚ or authorized to dispose of transferable property not his own‚ is competent to transfer such property either wholly or in part‚ and either absolutely or conditionally‚ in the circumstances‚ to the extent and in the manner‚ allowed
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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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Heat transfer Heat transfer is the transition of thermal energy from a hotter object to a cooler object ("object" in this sense designating a complex collection of particles which is capable of storing energy in many different ways). When an object or fluid is at a different temperature than its surroundings or another object‚ transfer of thermal energy‚ also known as heat transfer‚ or heat exchange‚ occurs in such a way that the body and the surroundings reach thermal equilibrium‚ this means that
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acceptance are different in the two environments. When a seller advertises goods for sale on a Web site‚ that seller is not making an offer‚ but is inviting others from potential buyers. When a buyer submits an order‚ which is an offer‚ the seller can accept that offer and create a contract. If the seller does not have the ordered items in stock‚ the seller
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