Transfer Mispricing
   HOME
*





Transfer Mispricing
Transfer mispricing, also known as transfer pricing manipulation or fraudulent transfer pricing, refers to trade between related parties at prices meant to manipulate markets or to deceive tax authorities. The legality of the process varies between tax jurisdictions; most regard it as a type of fraud or tax evasion. Generally, if two independent, unrelated parties negotiate with one other for a financial transaction and eventually reach a price, a transaction in correct market price will take place. According to the arm's length principle, the price at which the transaction occurs is preferred for tax purposes, as it is a fair reflection of the value of the goods or services. However, when the parties that negotiate a transaction are related, they may set an artificially lower price with the intention to minimise their taxes. Because of these tax benefits, transfer mispricing is favored by a majority of large enterprises. Examples Assume company ''A'', a multinational w ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


picture info

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]  


picture info

Globalization
Globalization, or globalisation (Commonwealth English; see spelling differences), is the process of interaction and integration among people, companies, and governments worldwide. The term ''globalization'' first appeared in the early 20th century (supplanting an earlier French term ''mondialization''), developed its current meaning some time in the second half of the 20th century, and came into popular use in the 1990s to describe the unprecedented international connectivity of the post-Cold War world. Its origins can be traced back to 18th and 19th centuries due to advances in transportation and communications technology. This increase in global interactions has caused a growth in international trade and the exchange of ideas, beliefs, and culture. Globalization is primarily an economic process of interaction and integration that is associated with social and cultural aspects. However, disputes and international diplomacy are also large parts of the history of globalizat ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


picture info

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 prevailing o ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


picture info

Base Erosion And Profit Shifting
Base erosion and profit shifting (BEPS) refers to corporate tax planning strategies used by multinationals to "shift" profits from higher-tax jurisdictions to lower-tax jurisdictions or no-tax locations where there is little or no economic activity, thus "eroding" the "tax-base" of the higher-tax jurisdictions using deductible payments such as interest or royalties. For the government, the tax base is a company's income or profit. Tax is levied as a percentage on this income/profit. When that income / profit is transferred to another country or tax haven, the tax base is eroded and the company does not pay taxes to the country that is generating the income. As a result, tax revenues are reduced and the government is detained. The Organization for Economic Co-operation and Development (OECD) define BEPS strategies as "exploiting gaps and mismatches in tax rules". While some of the tactics are illegal, the majority are not. Corporate tax havens offer BEPS tools to "shift" pr ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


picture info

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]  


picture info

Tax Haven
A tax is a compulsory financial charge or some other type of levy imposed on a taxpayer (an individual or legal entity) by a governmental organization in order to fund government spending and various public expenditures (regional, local, or national), and tax compliance refers to policy actions and individual behaviour aimed at ensuring that taxpayers are paying the right amount of tax at the right time and securing the correct tax allowances and tax reliefs. The first known taxation took place in Ancient Egypt around 3000–2800 BC. A failure to pay in a timely manner ( non-compliance), along with evasion of or resistance to taxation, is punishable by law. Taxes consist of direct or indirect taxes and may be paid in money or as its labor equivalent. Most countries have a tax system in place, in order to pay for public, common societal, or agreed national needs and for the functions of government. Some levy a flat percentage rate of taxation on personal annual income, but mo ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


Switzerland
). Swiss law does not designate a ''capital'' as such, but the federal parliament and government are installed in Bern, while other federal institutions, such as the federal courts, are in other cities (Bellinzona, Lausanne, Luzern, Neuchâtel, St. Gallen a.o.). , coordinates = , largest_city = Zürich , official_languages = , englishmotto = "One for all, all for one" , religion_year = 2020 , religion_ref = , religion = , demonym = , german: Schweizer/Schweizerin, french: Suisse/Suissesse, it, svizzero/svizzera or , rm, Svizzer/Svizra , government_type = Federalism, Federal assembly-independent Directorial system, directorial republic with elements of a direct democracy , leader_title1 = Federal Council (Switzerland), Federal Council , leader_name1 = , leader_title2 = , leader_name2 = Walter Thurnherr , legislature = Fe ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


picture info

Dubai
Dubai (, ; ar, دبي, translit=Dubayy, , ) is the most populous city in the United Arab Emirates (UAE) and the capital of the Emirate of Dubai, the most populated of the 7 emirates of the United Arab Emirates.The Government and Politics of the Middle East and North Africa. D Long, B Reich. p.157 Established in the 18th century as a small fishing village, the city grew rapidly in the early 21st century with a focus on tourism and luxury, having the second most five-star hotels in the world, and the tallest building in the world, the Burj Khalifa, which is tall. In the eastern Arabian Peninsula on the coast of the Persian Gulf, it is also a major global transport hub for passengers and cargo. Oil revenue helped accelerate the development of the city, which was already a major mercantile hub. A centre for regional and international trade since the early 20th century, Dubai's economy relies on revenues from trade, tourism, aviation, real estate, and financial services.
[...More Info...]       [...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


picture info

Cooperation
Cooperation (written as co-operation in British English) is the process of groups of organisms working or acting together for common, mutual, or some underlying benefit, as opposed to working in competition for selfish benefit. Many animal and plant species cooperate both with other members of their own species and with members of other species (symbiosis or mutualism). Among humans Humans cooperate for the same reasons as other animals: immediate benefit, genetic relatedness, and reciprocity, but also for particularly human reasons, such as honesty signaling (indirect reciprocity), cultural group selection, and for reasons having to do with cultural evolution. Language allows humans to cooperate on a very large scale. Certain studies have suggested that fairness affects human cooperation; individuals are willing to punish at their own cost (''altruistic punishment'') if they believe that they are being treated unfairly. Sanfey, et al. conducted an experiment where 19 ind ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


picture info

International Agreements
A treaty is a formal, legally binding written agreement between actors in international law. It is usually made by and between sovereign states, but can include international organizations, individuals, business entities, and other legal persons. A treaty may also be known as an international agreement, protocol, covenant, convention, pact, or exchange of letters, among other terms. However, only documents that are legally binding on the parties are considered treaties under international law. Treaties vary on the basis of obligations (the extent to which states are bound to the rules), precision (the extent to which the rules are unambiguous), and delegation (the extent to which third parties have authority to interpret, apply and make rules). Treaties are among the earliest manifestations of international relations, with the first known example being a border agreement between the Sumerian city-states of Lagash and Umma around 3100 BC. International agreements were used in so ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


Guidelines
A guideline is a statement by which to determine a course of action. A guideline aims to streamline particular processes according to a set routine or sound practice. Guidelines may be issued by and used by any organization (governmental or private) to make the actions of its employees or divisions more predictable, and presumably of higher quality. A guideline is similar to a rule, but are legally less binding as justified deviations are possible. List of guidelines Examples of guidelines are: * Code of practice * EASE Guidelines for Authors and Translators of Scientific Articles * Federal Sentencing Guidelines * Guidelines for Examination in the European Patent Office * Medical guidelines * Publicly Available Specification * Programming style guidelines * UNGEGN Toponymic Guidelines The United Nations Group of Experts on Geographical Names (UNGEGN) is one of the nine expert groups of the United Nations Economic and Social Council (ECOSOC) and deals with the national and i ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]  


picture info

OECD
The Organisation for Economic Co-operation and Development (OECD; french: Organisation de coopération et de développement économiques, ''OCDE'') is an intergovernmental organisation with 38 member countries, founded in 1961 to stimulate economic progress and world trade. It is a forum whose member countries describe themselves as committed to democracy and the market economy, providing a platform to compare policy experiences, seek answers to common problems, identify good practices, and coordinate domestic and international policies of its members. The majority of OECD members are high-income economies with a very high Human Development Index (HDI), and are regarded as developed countries. Their collective population is 1.38 billion. , the OECD member countries collectively comprised 62.2% of global nominal GDP (US$49.6 trillion) and 42.8% of global GDP ( Int$54.2 trillion) at purchasing power parity. The OECD is an official United Nations observer. In April 1948, ...
[...More Info...]      
[...Related Items...]     OR:     [Wikipedia]   [Google]   [Baidu]