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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]
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]
Gojek was started by Nadiem Makarim in 2010 as a call center and 20 ojeks (motorcycle taxi) to arrange transportation and courier deliveries. [15] In 2015, Gojek started an app which boosted the orders from 3,000 to 10,000 orders per day, and expanded the services including food delivery, ticket sales, etc. [15] In 2017, Gojek become Indonesia's first unicorn startup, with orders up to 300,000 ...
Research in September 2018, by the National Bureau of Economic Research, using repatriation tax data from the TCJA, said that: "In recent years, about half of the foreign profits of U.S. multinationals have been booked in tax haven affiliates, most prominently in Ireland (18%), Switzerland, and Bermuda plus Caribbean tax havens (8%–9% each). [2]
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.
ECJ held that Akzo had engaged in predatory pricing, and that a market share over 50% created a presumption of dominance. [2]60 With regard to market shares the Court has held that very large shares are in themselves, and save in exceptional circumstances, evidence of the existence of a dominant position (judgment in Case 85/76 Hoffman-La Roche v Commission [1979] ECR 461, paragraph 41).
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").
The JTPF was formally established by Commission Decision 2007/75/EC, [5] setting up an expert group on transfer pricing, which —after two updates— [4] [3] expired on 31 March 2019. The business (non-government) members of the forum (as of 6 Oct 2013) comprised 16 people. [ 6 ]
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