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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 ...
Speaking at the same conference, judge Vesna Tomljenović, who presided over the European General Court decision of 2020 in the Apple case, criticized the use of transfer pricing rules as a tool for tax planning, including in the case of Apple. [80]
The setting of the amount of related party charges is commonly referred to as transfer pricing. Many jurisdictions have become sensitive to the potential for shifting profits with transfer pricing, and have adopted rules regulating setting or testing of prices or allowance of deductions or inclusion of income for related party transactions.
Exit taxation (also known as an exit fee, exit payment, compensation payment or exit charge) is a payment made for discontinuation of certain economic activities within corporate groups, required in many tax jurisdictions by transfer pricing regulations. Within the European Union, exit taxation is provided for in Article 5 of Directive 2016/ ...
An advance pricing agreement (APA) is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology (TPM) for a set of transactions at issue over a fixed period of time [1] (called "Covered Transactions"). Most APAs involve U.S. taxpayers and the US Internal Revenue Service (IRS), but APAs are ...
Fraudulent transfer pricing, sometimes called transfer mispricing, ... The obvious way to do this is to frame tax rules so that there is a smaller scope for avoidance.
In 2007, it was suggested that the US Internal Revenue Service use formulary apportionment (actually a hybrid approach: routine return plus residual profit split) in the assessment of federal corporate income tax, believing it would lead to increased tax revenue in the face of a trend for multinational corporations to use transfer pricing to ...
Domestic international sales corporation. The domestic international sales corporation is a concept unique to tax law in the United States. In 1971, the U.S. Congress voted to use U.S. tax law to subsidize exports of U.S.-made goods. The initial mechanism was through a Domestic International Sales Corporation (DISC), an entity with no substance ...
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