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The discussion in this section explains an economic theory behind optimal transfer pricing with optimal defined as transfer pricing that maximizes overall firm profits in a non-realistic world with no taxes, no capital risk, no development risk, no externalities or any other frictions which exist in the real world.
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.
An advance pricing agreement (APA) is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology (TPM) for a set of transactions at issue over a fixed period of time [1] (called "Covered Transactions").
TP-based BEPS tools, [d] shifts profits to the haven by asserting that a process performed in the haven (e.g., contract manufacturing), justifies a large increase in the transfer price ("TP") at which the finished product is charged-out by the haven to higher-tax jurisdictions.
Wholesale funding is a method that banks use in addition to core demand deposits to finance operations, make loans, and manage risk. In the United States wholesale funding sources include, but are not limited to, Federal funds, public funds (such as state and local municipalities), U.S. Federal Home Loan Bank advances, the U.S. Federal Reserve's primary credit program, foreign deposits ...
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Actions 8-10: Transfer Pricing. Moves to align transfer pricing outcomes with value creation. Creates stronger guidelines to transactions involving the transfer pricing of intangibles and contractual arrangements. [51] Action 11: BEPS Data Analysis
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