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A frequently-proposed [107] [108] alternative to arm's-length principle-based transfer pricing rules is formulary apportionment, under which corporate profits are allocated according to objective metrics of activity such as sales, employees, or fixed assets. Some countries (including Canada and the United States) allocate taxing rights among ...
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.
The transactional net margin method (TNMM) in transfer pricing compares the net profit margin of a taxpayer arising from a non-arm's length transaction with the net profit margins realized by arm's length parties from similar transactions; and examines the net profit margin relative to an appropriate base such as costs, sales or assets.
Securities Transaction Tax (STT) is a tax payable in India on the value of securities (excluding commodities and currency) transacted through a recognized stock exchange. As of 2016, it is 0.1% for delivery based equity trading .
Additionally, companies do not have to record transfer prices for the EU tax authorities any longer. Thus, cross-border transactions within the EU would cease to give rise to specific tax costs due to conflicting qualifications. However, transfer pricing problems are replaced by allocation problems.
In order to correctly report the combined company post-acquisition, one needs to evaluate the assets and liabilities being acquired and their Fair Value ("FV") -- the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. The acquirer hires an ...
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Income shifted included investment income (interest and dividends) and passive income (rents and royalties), as well as sales and services income involving related parties (see transfer pricing). U.S. tax on this income was avoided until the tax haven country paid a dividend to the shareholding company.