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Tax avoidance
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(Buch) |
Dieser Artikel gilt, aufgrund seiner Grösse, beim Versand als 2 Artikel!
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| Source: Wikipedia. Pages: 62. Chapters: 1209 North Orange Street, 2008 Liechtenstein tax affair, Barter, Blocker corporation, Booze cruise, Bottom of the harbour tax avoidance, Cherry-picking tax avoidance, Corporate inversion, Cross-border leasing, Disposable ship, Double Irish arrangement, Estate planning, Federal Commissioner of Taxation v Peabody, Free trade zone, Furniss v. Dawson, Harmful Tax Competition: An Emerging Global Issue, Inter-American Center of Tax Administrations, Mauritius route, Misclassification of employees as independent contractors, Mullens v Federal Commissioner of Taxation, One-dollar salary, Perpetual traveler, Qualified personal residence trust, Ras al-Khaimah, Renunciation of citizenship, Reverse Morris Trust, Salary packaging, Shell corporation, Son of Boss, SUTA dumping, Tax exile, Tax haven, Tax Justice Network, Tax patent, Tax shelter, The Ramsay Principle, Transfer pricing, Ugland House, Uniform Gifts to Minors Act, Wash sale, Wealth Transfer Group, Window tax. Excerpt: Transfer pricing is a profit allocation method used to attribute a corporation's net profit or loss before tax to tax jurisdictions. Transfer prices are the charges made between controlled (or related) legal entities i.e. within the same group. Legal entities considered under the control of a single corporation include branches and companies that are wholly or majority owned ultimately by the parent corporation. Certain jurisdictions consider entities to be under common control if they share family members on their boards of directors. It refers to the setting, analysis, documentation, and adjustment of charges made between related parties for goods, services, or use of property (including intangible property). Transfer prices among components of an enterprise may be used to reflect allocation of resources among such components, or for other purposes. OECD Transfer Pricing Guidelines state, ¿Transfer prices are significant for both taxpayers and tax administrations because they determine in large part the income and expenses, and therefore taxable profits, of associated enterprises in different tax jurisdictions.¿ Over 60 governments have adopted transfer pricing rules. Transfer pricing rules in most countries are based on what is referred to as the ¿arm¿s length principle¿ ¿ that is to establish transfer prices based on analysis of pricing in comparable transactions between two or more unrelated parties dealing at arm¿s length. The OECD has published guidelines based on the arm's length principle, which are followed, in whole or in part, by many of its member countries in adopting rules. The United States and Canadian rules are similar in many respects to the OECD guidelines, with certain points of material difference. A few countries, such as Brazil and Kazakhstan, follow rules that are materially different overall. The rules of nearly all countries permit related parties to set prices in any manner, but permit the tax authorities to adjust those prices where the |
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