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The discussion in this section explains an economic theory behind optimal transfer pricing with optimal defined as transfer pricing that maximizes overall firm profits in a non-realistic world with no taxes, no capital risk, no development risk, no externalities or any other frictions which exist in the real world.
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]
PT Adaro Energy Indonesia Tbk is an Indonesian coal mining company, the country's second-largest by production volume and largest by market capitalisation. In the 2023 Forbes Global 2000 , Adaro Energy was ranked as the 1393th-largest public company in the world. [ 1 ]
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.
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.
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").
Soeryadjaya set up investment firm Saratoga Investama Sedaya in 1998. Today, through his private equity firm, PT Saratoga Investama Sedaya, he holds an ownership in coal miner Adaro Energy. He also has a stake in cell tower company Tower Bersama Infrastructure and bought Mandala Airlines in 2011 with his partner Sandiaga Uno. [1]
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).