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See searches and references containing TRANSFER PRICING!TRANSFER PRICING
Rules and methods for pricing transactions between enterprises under common ownership
Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of
Transfer_pricing
Measure of how contributions make up an institution's profitability
The Fund Transfer Pricing (FTP) measures the contribution by each source of funding to the overall profitability in a financial institution. Funds that
Funds_transfer_pricing
Tax dispute involving Apple, Ireland, and the EU
of four people. The Commissioners noted concerns that discretion in transfer pricing rules had been used to give Apple selective advantage. They believed
Apple–EU_tax_dispute
Parties to a transaction are on an equal footing
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
Arm's_length_principle
Method of tax evasion or fraud
Transfer mispricing, also known as transfer pricing manipulation or fraudulent transfer pricing, refers to trade between related parties at prices meant
Transfer_mispricing
Taxation between countries
shifting income among commonly controlled parties, often referred to as transfer pricing rules. Residency-based systems are subject to taxpayer attempts to
International_taxation
Field of business administration, part of the internal accounting system of a company
industry is manufacturing-based or service-oriented. For example, transfer pricing is a concept used in manufacturing but is also applied in banking.
Management_accounting
English economist (1940–2017)
No. 3. Autumn. 1977 pp 101-121 Robin Murray, Transfer pricing and the State, Conference on Transfer Pricing, IDS, 6–10 March 1978 Robin Murray, "The Chandarias:
Robin_Murray_(economist)
An advance pricing agreement (APA) is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology
Advance_pricing_agreement
American author, academic, accountant
of transfer pricing, Ronen points out a strong similarity between the problems of dealing with externalities and the intra-firm transfer pricing problem
Joshua_Ronen
Intergovernmental economic organisation
Additionally, the OECD has published and updated the Transfer Pricing Guidelines since 1995. The Transfer Pricing Guidelines serve as a template for the profit
OECD
Accounting transfer pricing tax method
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
Transactional net margin method
Transactional_net_margin_method
Process of determining what a company will receive in exchange for its products
approach to pricing (i.e., the pricing strategy), they turn their attention to pricing tactics. Tactical pricing decisions are shorter term prices, designed
Pricing
Lawsuit over Freedom of Information Act
Sullivan and the IRS. The IRS uses the services of the law firm to assess transfer pricing financial audits of Microsoft. The IRS had been investigating Microsoft
Microsoft Corp. v. Internal Revenue Service
Microsoft_Corp._v._Internal_Revenue_Service
Application of mathematical and statistical methods in finance
observed market prices as input. See: Valuation of options; Financial modeling; Asset pricing. The fundamental theorem of arbitrage-free pricing is one of the
Mathematical_finance
Canadian-American business manager
Law. Dr. Eden is an expert in the field of International Transfer Pricing, which is the pricing of products that move between subunits of Multinational
Lorraine_Eden
tax policy and tax advice from around the world. This remit includes transfer pricing, corporate tax and indirect tax, particularly VAT and sales tax. The
ITR_(magazine)
Standardised contract to buy or sell an asset at a future date
arguments ("rational pricing") apply when the deliverable asset exists in plentiful supply or may be freely created. Here, the forward price represents the
Futures_contract
Former pharmaceutical company merged with Allergan
company was criticized for legally moving its profits offshore via transfer pricing. "Forest Laboratories, Inc. 2013 Form 10-K Annual Report". U.S. Securities
Forest_Laboratories
2011 European Union common tax scheme proposal
qualifications. However, transfer pricing problems are replaced by allocation problems. Furthermore, the problems of transfer pricing do not vanish regarding
Common Consolidated Corporate Tax Base
Common_Consolidated_Corporate_Tax_Base
Academic discipline studying businesses and investments
capital; respectively: Asset pricing theory develops the models used in determining the risk-appropriate discount rate, and in pricing derivatives; and includes
Finance
Option's fixed price to exercise it on the expiration date
In finance, the strike price (or exercise price) of an option is a fixed price at which the owner of the option can buy (in the case of a call), or sell
Strike_price
Loss of tourist revenue from a country
use of foreign currency within their borders, reducing the effect of transfer pricing (see above). Many countries require visitors to have a certain amount
Leakage_effect
American economist
of the Berry Ratio, an analytical tool used extensively by tax and transfer pricing analysts over the world. Berry consulted with numerous government agencies
Charles_Berry_(economist)
countries tax authorities have implemented transfer pricing rules. Countries with specific rules on transfer pricing are less attractive from a corporate perspective
Tax_Attractiveness_Index
Type of financial contract
more complex derivatives, pricing involves developing a complex pricing model: understanding the stochastic process of the price of the underlying asset
Derivative_(finance)
Monetary contract between parties
which are readily transferable, and instruments such as loans and deposits, where both borrower and lender have to agree on a transfer. Derivative instruments
Financial_instrument
Banking valuation adjustments
XVA exposures. Historically, (OTC) derivative pricing has relied on the Black–Scholes risk neutral pricing framework which assumes that funding is available
XVA
Tax on corporations
setting of prices charged by related parties for goods, services or the use of property. Many jurisdictions have guidelines on transfer pricing which allow
Corporate_tax
Method of allocating corporate taxation between jurisdictions
revenue in the face of a trend for multinational corporations to use transfer pricing to shift profits out of the US into low-tax countries. None of these
Formulary_apportionment
Supreme Court of Canada case
ruling of the Supreme Court of Canada that deals with issues involving transfer pricing and how they are treated under the Income Tax Act of Canada ("ITA")
Canada_v_GlaxoSmithKline_Inc
System of surcharging users of public goods
has recently created greater interest in congestion pricing. Implementation of congestion pricing has reduced traffic congestion in urban areas, reduced
Congestion_pricing
Subset of technologies used in finance
management platforms. In the business-to-business (B2B) sector, usage-based pricing is prevalent, especially for API services. Financial technology infrastructure
Financial_technology
Corporation operating in multiple countries
up to 5% due to billions being transferred to corporate tax havens. While research has found that anti-transfer pricing may be effective in raising corporate
Multinational_corporation
Type of mutual fund or exchange-traded fund
foreknowledge of the large institutional block orders. This results in profits transferred from investors to algorithmic traders. In effect, an index, and consequently
Index_fund
such as sales suppression in domestic trade and missing trader fraud, transfer pricing in cross-border trade. As such, the implementation of this idea enables
Digital invoice customs exchange
Digital_invoice_customs_exchange
Loan secured using real estate
annually or monthly) adjust up or down to some market index. Adjustable rates transfer part of the interest rate risk from the lender to the borrower and thus
Mortgage
Defunct Indian telecommunications company
final chapter of the dispute by withdrawing its remaining ₹8,500-crore transfer pricing case against Vodafone India Services before the Supreme Court of India
Vodafone_India
Professionally managed investment fund
investors join or leave the fund, the costs (both trading costs and stale pricing) are borne by all investors in the fund Sometimes investors in mutual funds
Mutual_fund
Central government agency in India
agreements and various other aspects of international taxation such as transfer pricing. Combating tax evasion and tax avoidance practices is a key duty of
Income_Tax_Department
Fee for vehicles entering part of Manhattan
Congestion pricing in New York City, also known as the Central Business District Tolling Program or CBDTP, began on January 5, 2025. It applies to most
Congestion pricing in New York City
Congestion_pricing_in_New_York_City
Overview of finance and finance-related topics
#Asset pricing theory above) Equilibrium price market efficiency economic equilibrium rational expectations Arbitrage-free price Rational pricing § Arbitrage
Outline_of_finance
UK tax on UK-resident companies and companies with permanent establishments in the UK
prices for tax purposes where they did not in fact take place as such.[citation needed] Merging thin capitalisation rules with the transfer pricing rules
United Kingdom corporation tax
United_Kingdom_corporation_tax
Selling unowned financial securities
stock in limited supply. This has important implications for derivatives pricing and strategy, for the borrow cost itself can become a significant convenience
Short_(finance)
Type of legal provision
certain minimum operational profits, are not made subject to rigorous transfer pricing audits. In the context of Information Technology Act, 2000, a safe
Safe_harbor_(law)
Multinational professional services network
legal helps clients increase their net asset value, undertake the transfer pricing and international tax activities of multinational companies, minimize
Deloitte
Mathematical framework for investment risk
are therefore given. (There are several approaches to asset pricing that attempt to price assets by modelling the stochastic properties of the moments
Modern_portfolio_theory
Belgian economist and law professor
workshop at . Zuhai on 'control of transfer pricing manipulations' -Editor of book of readings on ‘'Transfer Pricing and International Taxation', vol.14
Sylvain_Plasschaert
Indian lawyer
clients in all areas of taxation, including International Taxation and Transfer Pricing, Goods and Services Tax, Customs, Excise, Service Tax, Value Added
V._Lakshmikumaran
Possibility that a debtor country might gain by making payments to its creditor countries
international trade articles Transfer pricing Barry W. Ickes. (2009). The Transfer Problem Yves Balasko, (2014). The transfer problem: A complete characterization
Transfer_problem
2012 OECD project to combat BEPS
8-10: Transfer Pricing Moves to align transfer pricing outcomes with value creation. Creates stronger guidelines to transactions involving the transfer pricing
Base erosion and profit shifting (OECD project)
Base_erosion_and_profit_shifting_(OECD_project)
Irish professional services company
paid $200 million to Swiss authorities over tax claims related to transfer pricing arrangements. In August 2021, Accenture confirmed a data breach resulting
Accenture
centuries led to the introduction of management practices, such as transfer pricing, to improve the efficiency of anesthetists. In ancient Greek texts
History_of_general_anesthesia
Professional credential
treaties, a select number of countries’ international tax regimes, Transfer Pricing, the cross-border taxation of the banking and energy sectors, and transnational
Advanced Diploma in International Taxation
Advanced_Diploma_in_International_Taxation
Internal rent is a form of transfer pricing where a company owning its own premises forces single departments in that company to pay rent for the real
Internal_rent
Development Trade finance Trade pact Trade sanctions Trade war Transfer pricing Transfer problem United Nations Monetary and Financial Conference Uruguay
Index of international trade articles
Index_of_international_trade_articles
Levying of compulsory charges on the same thing by two different jurisdictions
provisions to facilitate relieving of economic double taxation in transfer pricing cases. This is a taxpayer friendly measure and is in line with India's
Double_taxation
Political philosophy
Redistribution of income and wealth is the transfer of income and wealth (including physical property) from some individuals to others through a social
Redistribution of income and wealth
Redistribution_of_income_and_wealth
Economic service provided by the finance industry
– where clients can purchase and sell foreign currency banknotes. Wire transfer – where clients can send funds to international banks abroad. Remittance
Financial_services
Term in economics
valuation, benefit value transfers, and revealed preferences which includes hedonic pricing and travel cost method. Shadow pricing is frequently used to
Shadow_price
activities within corporate groups, required in many tax jurisdictions by transfer pricing regulations. Within the European Union, exit taxation is provided for
Corporate_exit_tax
Investment paradigm
be patient for the rest of the market to recognize and correct whatever pricing issue created the momentary value. Eveillard correctly labels the use of
Value_investing
Position in a financial instrument in which the holder owns a positive amount
at the contract price at expiry. The holder of the position will profit if the price of the underlying instrument goes up, as the price he will pay will
Long_(finance)
Economic theory that asset prices fully reflect all available information
risk-based theories of asset prices, and frameworks such as consumption-based asset pricing and intermediary asset pricing can be thought of as the combination
Efficient-market_hypothesis
Organization that provides services for stock brokers and traders to trade securities
are driven by various factors that, as in all free markets, affect the price of stocks (see stock valuation). There is usually no obligation for stock
Stock_exchange
American scholar
planning audit programs. Abdel-khalik studied Myron Gordon's model of transfer pricing system and published a paper indicating that Gordon's model could,
Ahmed_Rashad_Abdel-khalik
Company owned or controlled primarily by taxpayers of a different jurisdiction
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
Controlled foreign corporation
Controlled_foreign_corporation
Any of various types of risk associated with financing
market movements Arbitrage pricing theory – Asset pricing theory Beta – Second letter of the Greek alphabet Capital asset pricing model – Finance model linking
Financial_risk
American businessman and investor (born 1956)
had been looking into how Microsoft and other companies deal with transfer pricing. In December 2023, CNN estimated that Ballmer was set to collect $1
Steve_Ballmer
Investment position used to offset potential losses in another asset
at a price decided now. Non-deliverable forwards (NDF): A strictly risk-transfer financial product similar to a forward rate agreement, but used only where
Hedge_(finance)
Finnish multinational corporation
officials grill Price Waterhouse". Business Line. Chennai. Retrieved 31 January 2013. "Nokia suspected of flouting transfer pricing rules too". Business
Nokia
Bribing scandal involving the Chinese branch of drugmaker company GlaxoSmithKline
then sent the prices in China to GSK's transfer pricing (TP) center to calculate the importing prices and cost prices. When the prices were approved by
GSK_China_scandal
Canada uranium company
financialpost. Retrieved 2023-04-21. "Key takeaways from Supreme Court's termination of Cameco transfer pricing saga". BLG. Retrieved 2023-04-21. Official website
Cameco
Topics referred to by the same term
National Liberation Front, a Nicaraguan political party founded in 1961 Transfer pricing, a concept in taxation Traffic police, cops who enforce the rules of
TP
Form of taxation in the United States
a jurisdiction, they are subject to transfer pricing rules. Under these rules, tax authorities may adjust prices charged between related parties under
Corporate tax in the United States
Corporate_tax_in_the_United_States
Process of planning for inheritance of property
gift tax, capital gains tax, inheritance tax, and generation-skipping transfer tax plays a significant role in choosing the structure and vehicles used
Estate_planning
American economist
German firms to competition from low-cost countries such as China, transfer pricing decisions by US-based multinationals, and the effects of tariff and
Andrew_Bernard
Chicago-based digital media company
dividends paid to its owners in cash or in the form of below market transfer pricing for the sale of digital marketing products sold in its local affiliate
Classified_Ventures
Microeconomic pricing strategy to maximise firm profits
healthcare. Price discrimination is also referred to as differential pricing, equity pricing, preferential pricing, segmented pricing, dual pricing, and tiered
Price_discrimination
Income return on an investment expressed as a percentage of its value
return on an investment, the other component being the change in the market price of the security. It is a measure applied to fixed income securities, common
Yield_(finance)
Tax based on taxable income
Miranda (June 6, 2016). "Income Tax at 100 Years: A Little History". Tax and Transfer Policy Institute. Australian National University. Bowman, Linda (1993)
Income_tax
Topics referred to by the same term
algorithm for scheduling project activities Comparable profits method, a transfer pricing method Christian Political Movement, a South African political party
CPM
Financial failure to meet legal conditions of a loan
ISBN 0-07-141755-9. Duffie, Darrell; Kenneth J. Singleton (2003). Credit Risk: Pricing, Measurement, and Management. Princeton University Press. ISBN 0-691-09046-7
Default_(finance)
Academic discipline concerned with the exchange of money
models. Rational pricing is the assumption that asset prices (and hence asset pricing models) will reflect the arbitrage-free price of the asset, as any
Financial_economics
American multinational food conglomerate
Last10K. Retrieved August 1, 2019. "Argentine Tax Court ruling on Transfer Pricing Case". WTS Global. January 16, 2023. Retrieved June 6, 2026. Argentina
Cargill
Form of short-term borrowing
transaction, the ownership and possession of S are transferred at tN from a A to B and in tF transferred back from B to A; conversely, in the collateralized
Repurchase_agreement
Quantity theory of money Rate of return pricing – Rational choice theory – Rational expectations – Rational pricing – Reaganomics – Real business-cycle theory
Index_of_economics_articles
Sports action in which a player moves between clubs
general, players can only be transferred during a transfer window and according to the rules set by a governing body. A transfer fee is the agreed financial
Transfer (association football)
Transfer_(association_football)
Rules or restrictions for financial institutions
floor of exchanges is conducted in a proper manner. Most prominent the pricing process, execution and settlement of trades, direct and efficient trade
Financial_regulation
Single-price auctions are a pricing method in securities auctions that give all purchasers of an issue the same purchase price. They can be perceived
Single-price_auction
Budget tweak and redistribution of income
liberalized most of the pricing power, and the enterprises have a large amount of free pricing power. The free pricing system based on free prices has basically
Tax_shift
Company with few, if any, actual assets or operations
avoidance. A classic tax avoidance operation may utilize favorable transfer pricing among multiple corporate entities to lower tax liability in a certain
Shell_corporation
Payment for the right to harvest timber
pdf Sedjo, R. A. (2006). Comparative Views of Different Stumpage Pricing Systems: Canada and the United States. Forest science, 52(4), 446-450.
Stumpage
Economics concept
was published in 1982 under the title "A test of the intertemporal asset pricing model". The authors found that a standard general equilibrium model, calibrated
Equity_premium_puzzle
Multinational tax avoidance tools
actively involved in the BEPS Project. In 2015, the G20 supported the transfer pricing recommendations, which aims to guide governments on how profits of
Base erosion and profit shifting
Base_erosion_and_profit_shifting
Amount that one may deduce from taxable revenue
foreign parties, especially related parties. See International tax and Transfer pricing. Piper, Mike (Sep 12, 2014). Taxes Made Simple: Income Taxes Explained
Tax_deduction
Penalties for non-payment of tax in the United States
substantial understatement of tax, substantial valuation misstatements, transfer pricing adjustments, or negligence or disregard of rules or regulations. For
IRS_penalties
2024 Chicago tax referendum for homelessness prevention services
the transfer price, or fraction thereof, for that part of the transfer price under $1,000,000 to be paid by the buyer of the real estate transferred unless
Bring_Chicago_Home
Amount of a certain security, commodity or currency held or owned by a person/entity
instruments, such as securities, currencies or commodities, for a given price. In derivatives trading or for financial instruments, the concept of a position
Position_(finance)
allocated to the DISC is reduced. The pricing rules in the law and regulation are independent of the transfer pricing rules normally applicable to transactions
Domestic international sales corporation
Domestic_international_sales_corporation
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