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References in periodicals archive ?
Transfer pricing concerns the determination of prices used by companies belonging to the same multinational group in their cross-border transactions.
In principle, this is simply a particularization, but not an extension, of the expectation in a tax statute that a taxpayer accurately calculate and report its income, and be prepared to offer an explanation in this regard informatively documented in its financial records.(51) In short, the new transfer pricing rules and practices, as have their precursors, encompass the not-surprising expectation that a taxpayer be prepared to explain in a deliberate, organized, and coherent way how its income was earned and why its reported income is consistent with its characteristics and contribution -- in relation to its activities and responsibilities in a tax jurisdiction -- to a functionally integrated multinational enterprise, relative to other members of its multinational group.
In early 1994, in an unusual joint statement, the Department of Finance and Revenue Canada issued a warning to Canadian members of multinational groups involving units in the United States that periodic adjustment in respect of licenses of intangibles or the comparable profits method - as set out in the temporary section 482 regulations - are not considered acceptable methods of determining arm's-length prices and their use could lead to conflict with Revenue Canada.(14) The Canadian government has not formally commented on the final U.S.
A German stock dividend is a relatively easy way to obtain a German cash refund and corresponding reduction in a multinational group's effective German tax rate.
These centres are companies established in Belgium and belonging to a multinational group. Their exclusive objective is to provide certain services (financing, management, treasury, etc.) for other companies from the same group.
EU Competition chief Mario Monti and the Belgian Government have reached a deal to phase out the preferential tax regime for co-ordination centres, which are companies that provide financial services to other firms in a multinational group, following concerns raised by the European Commission a year ago (see issue 2770).
In the case of a privately held diverse multinational group, the headquarters test will often prove to be the easiest test to satisfy under the Netherlands-2 Treaty.
A co-ordination centre provides marketing, advertising, public relations, accounting and other services to companies of the same foreign multinational group. The taxable profit of the co-ordination centre is established according to the cost-plus method.
The latter are undertakings belonging to a multinational group providing services to other members of the group.
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