Suchergebnisse

1. Contextual Considerations -- 2. The Concept of Transfer Pricing -- 3. Variable Terms and Conditions in Different Industries -- 4. Chinese Business Models -- 5. Transfer Pricing Methods -- 6. Company Preparation -- 7. Policy Development on Transfer Pricing -- 8. International Tax Risks and Chinese Enterprises -- 9. Using the Profit Split Method for Intangible Assets -- 10. Profit from Intangibles -- 11. An Issue for a High-Technology Company -- 12. Falling Transactions with Rising Fees -- 13. Tax Haven Victim -- 14. Exports on the Cheap -- 15. System Design for a Pharmaceutical Company -- 16. Expansion into Asia -- 17. A Company Converting to Realism -- 18. Footsteps to Fortune -- 19. Dates of Payment as an Asset -- 20. Obvious Methods May Not Apply -- 21. Clearly Exported Profits -- 22. The Intricacies of Transferring Service Assets -- 23. Supermarket Implants -- 24. Investigation of High Profit Company -- 25. Research and Development in Beijing -- 26. Outbound Service Fee Payment in Qingdao City -- 27. Value Chain Analysis Investigation in Shenyang City -- 28. A Linear Regression Approach for Adjusting Transfer Pricing -- 29. Resale Prices in Test of Transfer Pricing -- 30. Transfer Pricing Adjustments and Differential Products -- 31. Significant Payments of Royalties -- 32. Domestic Related Company Transactions -- 33. Royalty Fees Transferring Profits -- 34. Global Financial Crisis Only an Excuse -- 35. Direct View of Priorities -- 36. For the Future

Very little attention has been paid to transfer pricing issues in the financial services sector Europe‐wide. This article reports on transfer pricing choices of UK deposit‐taking institutions. It is based on the results of an exploratory survey carried out on UK‐based banks and building societies. The main aim is to investigate their transfer pricing methods and objectives as well as the structure and line of responsibility for their transfer pricing decisions. The results of the survey reveal that the achievement of overall corporate goals is the highest ranked transfer pricing objective. Market pricing is the most widely used method among the institutions. Salient differences were however found between the transfer pricing choices of banks, on the one hand, and building societies, on the other.

This monograph provides a comprehensive critical comparative study of legal regulations of transfer pricing in the V4 countries (the Czech Republic, Hungary, Poland and Slovakia). The monograph consists of two basic parts: conceptual and empirical. The empirical investigation itself is based on a qualitative research approach – above all, on comparative analysis approach for its methodology, which is in keeping with a qualitative research design. The subject being compared is transfer pricing in V4 countries with a focus given on to the rules governing transfer pricing in V4 countries as a strategic issue in the realized research. In the conceptual part of the monograph, the authors provide a literature overview for the issue of transfer pricing, a description of the design of empirical investigations and an overview of the basic standards as set by the OECD and EU. These parts of the monograph create a background for the empirical part which deals, among others, with the way the V4 countries adopted these standards. The empirical part of the monograph consists of the chapters dealing with the legal regulations of transfer pricing in particular V4 countries. These chapters also include a basic summary of the case-law related to transfer pricing issues and the identified problems and inadequacies in the legal regulations. In the following part of the monograph a comparison of transfer pricing regulations in the V4 countries is presented. The next part of the monograph comprises the policy implications for transfer pricing legal regulation for V4 countries.