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e. Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been ...
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. This ...
Arm's length principle: It is a key concept of most transfer pricing rules, that prices charged between related enterprises should be those which would be charged between unrelated parties dealing at arm's length. Most sets of rules prescribe methods for testing whether prices charged should be considered to meet this standard.
See also: Base erosion and profit shifting (OECD project) The 2012 G20 Los Cabos summit tasked the OECD to develop a BEPS Action Plan, [ 60 ][ 61 ] which 2013 G-20 St. Petersburg summit approved. [ 62 ] The project is intended to prevent multinationals from shifting profits from higher- to lower-tax jurisdictions. [ 63 ]
It is also one of the key elements in international taxation as it allows an adequate allocation of profit taxation rights among countries that conclude double tax conventions, through transfer pricing, among each other. Transfer pricing and the arm's length principle were one of the focal points of the base erosion and profit shifting (BEPS ...
Dumping, in economics, is a form of predatory pricing, especially in the context of international trade. It occurs when manufacturers export a product to another country at a price below the normal price with an injuring effect. The objective of dumping is to increase market share in a foreign market by driving out competition and thereby ...
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