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Chinese transfer pricing rules apply to transactions between a Chinese business and domestic and foreign related parties. A related party includes enterprises meeting one of eight different tests, including 25% equity ownership in common, overlapping boards or management, significant debt holdings, and other tests.
The "Killer B" strategy is a tax-avoidance strategy that reduces a firm's taxes owed on the repatriation of foreign cash used in the acquisition of another firm through the classification of an acquisition as a reorganization provided by Section 368(a)(1)(B) of the Internal Revenue Code.
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]
A key issue in corporate tax is the setting of prices charged by related parties for goods, services or the use of property. Many jurisdictions have guidelines on transfer pricing which allow tax authorities to adjust transfer prices used. Such adjustments may apply in both an international and a domestic context.
The transfer pricing issues that the audit may involve include a cost sharing agreement (CSA) with respect to the sufficiency of buy-in payments by an offshore affiliate of Microsoft's in exchange for licensing intangibles.
The MLP's expansion initiatives continue to grow its volumes and earnings.
Transfer Pricing Center: a comprehensive research tool featuring the latest OECD, U.S., and international transfer pricing rules, guidance, news, and analysis. The Tax Directory: a directory of corporate tax professionals in the U.S. and the government officials who write, implement, and interpret tax laws in the U.S. and abroad
Government spending or expenditure includes all government consumption, investment, and transfer payments. [1] [2] In national income accounting, the acquisition by governments of goods and services for current use, to directly satisfy the individual or collective needs of the community, is classed as government final consumption expenditure.
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