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The interpretation numbers come from the Financial Accounting Board's Original Pronouncements as amended 2008/2009 Edition, volume 3. Also, consult this volume for detailed listing of amendments, deletions, and other changes to the individual interpretations prior to 2009 (when the Accounting Standards Codification was issued.)
Accounting for an Unused Investment Tax Credit—an interpretation of APB Opinions No. 2, 4, 11, and 16 Sept. 1978: Parts deleted; Superseded by FASB Statement 96, para. 203(l), and FASB Statement 109, para. 286(o) 26. Accounting for Purchase of a Leased Asset by the Lessee during the Term of the Lease—an interpretation of FASB Statement No. 13
The relevant 183 day period is either 183 days in a calendar year or in any period of 12 months, depending upon the particular treaty involved. So, for example, the Double Tax Treaty with the UK looks at a period of 183 days in the German tax year (which is the same as the calendar year); thus, a citizen of the UK could work in Germany from 1 ...
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, sometime abbreviated BEPS multilateral instrument, is a multilateral convention of the Organisation for Economic Co-operation and Development to combat tax avoidance by multinational enterprises (MNEs) through prevention of Base Erosion and Profit Shifting (BEPS).
There exist many examples of PTIAs. A notable one is the North American Free Trade Agreement (NAFTA). While the NAFTA agreement deals with a very broad set of issues, most importantly cross-border trade between Canada , Mexico and the United States , chapter 11 of this agreement covers detailed provisions on foreign investment similar to those ...
The method of analyzing comparability and what factors are to be considered varies slightly by type of transfer pricing analysis method. The guidelines for CUP include specific functions and risks to be analyzed for each type of transaction (goods, rentals, licensing, financing, and services).
In particular, firms need to choose the method that "least likely overstates assets and income or understates liabilities and losses" [3] when encountering accounting issues. For example, if the staff believe there will be 2% bad debt in terms of receivables based on historical information and another staff believe there will be 5% because of a ...
Article 38(1) of the Statute of the International Court of Justice is generally recognized as a definitive statement of the sources of international law. [2] It requires the Court to apply, among other things, (a) international conventions, whether general or particular, establishing rules expressly recognized by the contesting states; (b) international custom, as evidence of a general ...