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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]
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 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.
Tomy Winata (pronounced [ˈtomi wiˈnata] and sometimes misspelled as Tommy Winata; born Guo Shuo Feng, Chinese: 郭說鋒 on 23 July 1958) is an Indonesian businessman with interests in banking, property, and infrastructure, whose wealth comes from his business deals for the Indonesian Military.
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).
The EU Joint Transfer Pricing Forum (JTPF) was an informal body set up to assist and advise the European Commission on transfer pricing tax matters. It has since been discontinued. [ 1 ] The JTPF was set up in 2002 from an EU communication . [ 2 ]
An international commodity agreement is an undertaking by a group of countries to stabilize trade, supplies, and prices of a commodity for the benefit of participating countries.