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Transactional Net Margin Method
The transactional net margin method (TNMM) in transfer pricing compares the net profit margin of a taxpayer arising from a non-arm's length transaction with the net profit margins realized by arm's length parties from similar transactions; and examines the net profit margin relative to an appropriate base such as costs, sales or assets. This differs from the cost-plus and resale price methods that compare gross profit margins. However, the TNMM requires a level of comparability similar to that required for the application of the cost plus and resale price methods. Where the relevant information exists at the gross margin level, taxpayers should apply the cost plus or resale price method. Because the TNMM is a one-sided method, it is usually applied to the least complex party that does not contribute to valuable or unique intangible asset An intangible asset is an asset that lacks physical substance. Examples are patents, copyright, franchises, goodwill, trademarks, and trade ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Transfer Pricing
In taxation and accounting, transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length (the arm’s-length principle). The OECD and World Bank recommend intragroup pricing rules based on the arm’s-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative practice.World Bank pp. 35-51 Countries with transfer pricing legislation generally follow th''OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations''in most respects, although their rules can differ on some important details. Where adopted, transfe ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Profit Margin
Profit margin is a measure of profitability. It is calculated by finding the profit as a percentage of the revenue. \text = = There are 3 types of profit margins: gross profit margin, operating profit margin and net profit margin. * Gross Profit Margin is calculated as gross profit divided by net sales (percentage). Gross Profit is calculated by deducting the cost of goods sold (COGS) from the revenue, that is all the direct costs. This margin compares revenue to variable cost. It is calculated as: \text = \text - (\text + \text + \text) \text = \text - \text - \text \text = * Operating Profit Margin includes the cost of goods sold and is the earning before interest and taxes (EBIT) known as operating income divided by revenue. It is calculated as: \text = * Net profit margin is net profit divided by revenue. Net profit is calculated as revenue minus all expenses from total sales. \text = Overview Profit margin is calculated with selling price (or revenue) taken as base ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Arm's Length
The arm's length principle (ALP) is the condition or the fact that the parties of a transaction are independent and on an equal footing. Such a transaction is known as an "arm's-length transaction". It is used specifically in contract law to arrange an agreement that will stand up to legal scrutiny, even though the parties may have shared interests (e.g., employer-employee) or are too closely related to be seen as completely independent (e.g., the parties have familial ties). An arm's length relationship is distinguished from a fiduciary relationship, where the parties are not on an equal footing, but rather, power and information asymmetries exist. It is also one of the key elements in international taxation as it allows an adequate allocation of profit taxation rights among countries that conclude double tax conventions, through transfer pricing, among each other. Transfer pricing and the arm's length principle was one of the focal points of the Base Erosion and Profit Sh ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Net Profit
In business and accounting, net income (also total comprehensive income, net earnings, net profit, bottom line, sales profit, or credit sales) is an entity's income minus cost of goods sold, expenses, depreciation and amortization, interest, and taxes for an accounting period. It is computed as the residual of all revenues and gains less all expenses and losses for the period,Stickney, et al. (2009) Financial Accounting: An Introduction to Concepts, Methods, and Uses. Cengage Learning and has also been defined as the net increase in shareholders' equity that results from a company's operations.Needles, et al. (2010) Financial Accounting. Cengage Learning. It is different from gross income, which only deducts the cost of goods sold from revenue. For households and individuals, net income refers to the (gross) income minus taxes and other deductions (e.g. mandatory pension contributions). Definition Net income can be distributed among holders of common stock as a dividend or ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Cost-plus Pricing
Cost-plus pricing is a pricing strategy by which the selling price of a product is determined by adding a specific fixed percentage (a " markup") to the product's unit cost. Essentially, the markup percentage is a method of generating a particular desired rate of return. An alternative pricing method is value-based pricing. Cost-plus pricing has often been used for government contracts (cost-plus contracts), and has been criticized for reducing incentive for suppliers to control direct costs, indirect costs and fixed costs whether related to the production and sale of the product or service or not. Companies using this strategy need to record their costs in detail to ensure they have a comprehensive understanding of their overall costs. This information is necessary to generate accurate cost estimates. Cost-plus pricing is especially common for utilities and single-buyer products that are manufactured to the buyer's specification, such as for military procurement. Mechanics ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Gross Margin
Gross margin is the difference between revenue and cost of goods sold (COGS), divided by revenue. Gross margin is expressed as a percentage. Generally, it is calculated as the selling price of an item, less the cost of goods sold (e. g. production or acquisition costs, not including indirect fixed costs like office expenses, rent, or administrative costs), then divided by the same selling price. "Gross margin" is often used interchangeably with "gross profit", however the terms are different: "gross ''profit''" is technically an absolute monetary amount and "gross ''margin''" is technically a percentage or ratio. Gross margin is a kind of profit margin, specifically a form of profit divided by net revenue, e. g., gross (profit) margin, operating (profit) margin, net (profit) margin, etc. Purpose The purpose of margins is "to determine the value of incremental sales, and to guide pricing and promotion decision."Farris, Paul W.; Neil T. Bendle; Phillip E. Pfeifer; David J. Re ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Intangible Asset
An intangible asset is an asset that lacks physical substance. Examples are patents, copyright, franchises, goodwill, trademarks, and trade names, as well as software. This is in contrast to physical assets (machinery, buildings, etc.) and financial assets (government securities, etc.). An intangible asset is usually very difficult to valuate. They suffer from typical market failures of non- rivalry and non-excludability.Webster, Elisabeth; Jensen, Paul H. (2006). ''Investment in Intangible Capital: An Enterprise Perspective.'' The Economic Record, Vol. 82, No. 256, March, 82-96. Today, a large part of the corporate economy ( NPV) consists of intangible assets. Definition Intangible assets may be one possible contributor to the disparity between "company value as per their accounting records", as well as "company value as per their market capitalization". Considering this argument, it is important to understand what an intangible asset truly is in the eyes of an accountant. A ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Pricing
Pricing is the process whereby a business sets the price at which it will sell its products and services, and may be part of the business's marketing plan. In setting prices, the business will take into account the price at which it could acquire the goods, the manufacturing cost, the marketplace, competition, market condition, brand, and quality of product. Pricing is a fundamental aspect of product management and is one of the four Ps of the marketing mix, the other three aspects being product, promotion, and place. Price is the only revenue generating element amongst the four Ps, the rest being cost centers. However, the other Ps of marketing will contribute to decreasing price elasticity and so enable price increases to drive greater revenue and profits. Pricing can be a manual or automatic process of applying prices to purchase and sales orders, based on factors such as: a fixed amount, quantity break, promotion or sales campaign, specific vendor quote, price prevai ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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