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  2. Transfer pricing - Wikipedia

    en.wikipedia.org/wiki/Transfer_pricing

    Transfer pricing adjustments have been a feature of many tax systems since the 1930s. The United States led the development of detailed, comprehensive transfer pricing guidelines with a White Paper in 1988 and proposals in 1990–1992, which ultimately became regulations in 1994. [33]

  3. Funds transfer pricing - Wikipedia

    en.wikipedia.org/wiki/Funds_Transfer_Pricing

    The Fund Transfer Pricing (FTP) measures the contribution by each source of funding to the overall profitability in a financial institution. [1] Funds that go toward lending products are charged to asset-generating businesses whereas funds generated by deposit and other funding products are credited to liability-generating businesses.

  4. Transfer mispricing - Wikipedia

    en.wikipedia.org/wiki/Transfer_mispricing

    Whereas appropriate transfer pricing of tangible goods can be established by comparison with prices charged for similar goods to unrelated parties, transfer pricing of intangible goods, products of intellectual efforts, rarely has comparable equivalents. Transfer prices then have to be established based on expectations of future income. [16]

  5. Transactional net margin method - Wikipedia

    en.wikipedia.org/wiki/Transactional_net_margin...

    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.

  6. Arm's length principle - Wikipedia

    en.wikipedia.org/wiki/Arm's_length_principle

    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 were one of the focal points of the base erosion and profit shifting (BEPS ...

  7. Base erosion and profit shifting - Wikipedia

    en.wikipedia.org/wiki/Base_erosion_and_profit...

    In 2015, the G20 supported the transfer pricing recommendations, which aims to guide governments on how profits of multinational companies should be divided among individual countries. Furthermore, the G20 is involved in developing a global tax framework.

  8. Apple's EU tax dispute - Wikipedia

    en.wikipedia.org/wiki/Apple's_EU_tax_dispute

    According to PwC, the full report by the European Commission contained very detailed analysis of the transfer pricing methodology used by Apple. According to the commission, the tax arrangement between Ireland and Apple qualifies as state aid as it meets the European Union's four criteria: [50] There has been an intervention by the State

  9. Asymmetric price transmission - Wikipedia

    en.wikipedia.org/wiki/Asymmetric_price_transmission

    Asymmetric price transmission (sometimes abbreviated as APT and informally called "rockets and feathers" , also known as asymmetric cost pass-through) refers to pricing phenomenon occurring when downstream prices react in a different manner to upstream price changes, depending on the characteristics of upstream prices or changes in those prices.

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