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Transfer pricing refers to the rules and methods for pricing transactions within and ... transfer pricing rules allow tax authorities to adjust prices for most cross ...
To ensure that these transactions are priced according to the arm's length principle, many countries tax authorities have implemented transfer pricing rules. Countries with specific rules on transfer pricing are less attractive from a corporate perspective because they provide less scope for profit shifting. [2]
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.
It also aims to ensure that goods and services provided by connected firms are transferred at arm's length and priced according to market circumstances, allowing earning to be reflected in the appropriate tax jurisdiction. [76] Transfer pricing in the U.S. is governed by section 482 of the Internal Revenue Code (IRC) and applies when two or ...
From 2010 to 2012, reports exposed flaws in 1990s transfer pricing rules, showing many corporations paid minimal taxes. This led to congressional hearings and the adoption of the G20 and OECD's base erosion and profit shifting (BEPS) initiative to reform transfer pricing and the international tax system. In response to the completion of the ...
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 which received tax benefits.
However, Belgian CFC legislation is obsolete in practice given that the application of Belgian transfer pricing rules (i.e. article 185, § 2 of the Belgian Income Tax Code, allowing the Belgian tax authorities to implement an upwards adjustment of the profits in case of a breach of the arm's length principle) take precedence over CFC legislation.
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