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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on discussion of adopting transfer pricing regime in Bangladesh and needed initiatives for it. In this regard it is necessary first to develop clear perception about the concepts related with the issue. Keeping in view this need this section consists of review of the literature that is focused on how to adopt transfer pricing regime in Bangladesh‚ what initiatives to follow to adopting transfer pricing regime. The section further unfolds the impacts of transfer pricing regime in Bangladesh and then
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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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The Fuqua School of Business Duke University International Strategy: WBA 434 Professors Heath‚ Huddart‚ & Slotta Transfer Pricing 1. Overview An essential feature of decentralized firms is responsibility centers (e.g.‚ cost-‚ profit-‚ revenue-‚ or investment-centers). The performance of these responsibility centers is evaluated on the basis of various accounting numbers‚ such as standard cost‚ divisional profit‚ or return on investment (as well as on the basis of other non-accounting measures‚ like
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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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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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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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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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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 Question 1) BADM4280 Paper Ltd. is a division of GH Inc. BADM4280 Paper Ltd. produces paper and sells it to a number of companies‚ as well as to GH Inc. who uses it in their textbook division. Recently‚ the vice president of marketing for GH Inc. approached BADM4280 Paper Ltd. with a request to make 20‚000 units of a special paper product. The following information is available regarding the BADM4280 Paper division: Selling price of regular paper per unit $80
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