Transper Pricing

ST/SG/AC.8/2001/CRP.6 ______________________________________________________________________________ 26 June 2001 English only ______________________________________________________________________________ Ad Hoc Group of Experts on International Cooperation in Tax Matters Tenth meeting Geneva, 10 - 14 September 2001 Transfer Pricing History C State of the Art C Perspectives * _________________________ * The present paper was nimble by the United Nations Secretariat. 2 1. Introduction This article intends to give the history and the causation for transfer pricing, an outline and comparison of the two main sources of rules in practice C the American Sec. 482 Regulations and the OECD Transfer Pricing Guidelines C and a view of the increasingly complicated future. From a fiscal perspective transfer pricing is probably the most beta tax issue in the world. Over 60 percentage of international trade is carried out within multinational enterprises (MNEs). The endpoint MNE in this context not only covers corporate moguls much(prenominal) as Shell, Mitsubishi, IBM, but also smaller companies with one or more subsidiaries or permanent establishments (PE) in countries other than that where the call forth company/head office is located.

Although parent companies of MNEs are subdued located to a great extent in essential countries, companies from developing countries, in particular in Asia, have started to blow a fuse abroad in recent years. Parent companies of larger groups commonly have sub-holdings and intermediary holdings in several countries; research and religious service activities may be concentrated in centers in operation(p) for the all group or specific parts; intangibles, veritable by group entities, may be concentrated in centers operating for the whole group or specific parts; intangibles, developed by group entities, may be concentrated at certain group members; finance companies may operate as internal banks; production of parts and assembly of final products may take place in... If you want to get a spacious essay, order it on our website: Ordercustompaper.com

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