Global ETD Search
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Showing 1 to 20 of 54 for “"Transfer pricing"”.
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Transfer pricing
"Today, transfer pricing is about the a/location of income of a multinational enterprise between nations. The introduction of anti-avoidance provisions were in th~ main sufficient to deter companies from shifting profit to overseas associates through under or over pricing of cross border …
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Three Essays on Transfer Pricing
… Enterprise's (or MNE's) behaviors under transfer pricing rules. The first essay studies the effects of transfer pricing rules on the decentralized MNE's use of transfer pricing as a strategic device for competition assuming that the choices of vertical foreclosure and vertical supply are …
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Optimized transfer-pricing model for Asia Pacific
Transfer price is an important field of study for profit maximization. As more multinational enterprises (MNEs) are involved in global trading in the recent decades, the objective to set an optimized transfer price is more crucial than ever since the difference in tax rates and tariffs have …
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Transfer Pricing in South African income tax law
'Transfer pricing continues to be, and will remain, the most important international tax issue facing MNEs.' The term 'transfer pricing' is used to describe arrangements involving the transfer of goods or services, at an artificial price, in order to transfer income or expenses from one enterprise …
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Behavioural aspects of transfer pricing in U.K. decentralised companies
… organisational and behavioural dimension of the transfer pricing problem as part of the management control process in the large decentralised company. The study examines the origin and developments of the problem through an extensive review of both the theoretical literature and a large number of …
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Managing international transfer pricing policies: a grounded theory study
The importance of international transfer pricing (ITP) has increased alongside the globalisation of business and the increasing importance of international trade and global marketing. During the 1990s,the OECD and numerous different countries (including the United Kingdom and the United States) …
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Tax implications of transfer pricing on supply chain management
… action by tax authorities world-wide to regulate transfer pricing, in order to protect their respective tax bases. As revenue authorities increase their focus on transfer pricing compliance, it is vital that multinationals adhere to the arm's length principle and ensure their transfer pricing …
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Transfer Pricing--Can It Effectively Be Applied To Computer Services?
… seeks to remedy this situation by applying transfer price to computer services. Procedure. The research procedure consisted of an analysis of transfer price theory and its varied applications. Next, the most generally accepted methods of transfer price theory were applied to an actual …
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Have the OECD Transfer Pricing Guidelines influenced the development of domestic legislation for transfer pricing and the outcome of court decisions in selected African states?
… for Economic Cooperation and Development (OECD) Transfer Pricing Guidelines (TPG) is a soft law instrument that acts as a guide to many multinational entities (MNE) in applying the arm's length principle (ALP). Amongst OECD member states, the OECD TPG is a relevant instrument to provide guidance …
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Curbing transfer pricing manipulation in South Africa : lessons from selected jurisdictions
Transfer pricing manipulation is a worldwide problem which results in a massive loss of revenue which is meant to finance government socio-economic programmes. South Africa is not immune to this problem. South Africa is losing billions of Rands in tax revenue due to this scourge. This research is …
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Transfer Pricing in East Africa: Tanzania and Kenya in Comparative Perspective
… obtaining tax has brought challenge in curbing transfer pricing manipulation arising out international transactions by associated MNCs. In the absence of aggressive tax legislation, human and financial resources, such countries are at high risk of losing substantial right share of tax due to …
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The suitability and practicality of the OECD transfer pricing methods to Zimbabwe
… between companies forms the foundation of the transfer pricing legislative regulatory framework in Zimbabwe. The arm's length principle (ALP) is the source of applying the provisions in the regulations. Reference to the Organisation of Economic Cooperation and Development (OECD) comprehensive …
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Transfer pricing: a comparison of the German and the South African system
… Preface of the 1996 Update to the OECD Report ,,Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations". This trend towards globalisation, together with South Africa's re-entry into the international economic community has lead to a significantly increasing demand for …
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Transfer pricing : an evaluation of section 31 of the Income Tax Act
… of the international principles relating to transfer pricing in its domestic legislation as encapsulated in section 31 of the Income Tax Act No. 58 of 1962. Transfer pricing is currently one of the more important short term international tax considerations, specifically in the South African …
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Factors affecting transfer pricing tax compliance in Zambia: evidence from the mining sector.
Multinational enterprises abuse transfer pricing to erode the country’s tax base by shifting profits to other jurisdictions thereby depriving the country of revenue that would otherwise be available for development. The aim of this study was to assess the factors affecting transfer pricing tax …
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Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector
… Economic Co-operation and Development ('OECD') transfer pricing methods and its application to Multinational Enterprise ('MNE') groups in the financial sector. This study examines whether the OECD's Base Erosion and Profit Shifting ('BEPS') Action Plan 9 is an appropriate framework for MNE …
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A study of the determinants of transfer pricing. The evaluation of the relationship between a number of company variables and transfer pricing methods used by UK companies in domestic and international markets
The transfer pricing, literature indicates that an investigation of some aspects of this subject could usefully be undertaken in order to contribute to the understanding of transfer pricing in both domestic and international markets. This study aims at exploring the current state of transfer …
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Transfer pricing and intangible assets: problem areas in addressing the transfer of intangible assets
… the problems that arise when the practice of transfer pricing is applied to the transfer of intangible asset transfers there are certain areas and nuances that need to be recognized. These include the distinction between economic and legal ownership and the fact that the two concepts, in …
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Exploring challenges with transfer pricing in South Africa: impact on government spent and income
Transfer pricing is a challenge for tax collection as taxpayers in multinational corporations may shift profits from affiliates in high-tax jurisdiction to their lower-tax jurisdiction counterparts (for tax avoidance), leading to reduced tax collected and therefore the country's financial muscle …
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