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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 ]
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]
Porter wrote in 1980 that strategy targets either cost leadership, differentiation, or focus. [1] These are known as Porter's three generic strategies and can be applied to any size or form of business.
An estimation of the CAPM and the security market line (purple) for the Dow Jones Industrial Average over 3 years for monthly data.. In finance, the capital asset pricing model (CAPM) is a model used to determine a theoretically appropriate required rate of return of an asset, to make decisions about adding assets to a well-diversified portfolio.
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 ]