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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).
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]
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 ]
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").
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 ]
In mathematical economics, the Arrow–Debreu model is a theoretical general equilibrium model. It posits that under certain economic assumptions (convex preferences, perfect competition, and demand independence), there must be a set of prices such that aggregate supplies will equal aggregate demands for every commodity in the economy.