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Book Categories |
Tables and Figures | ||
Preface | ||
I | Introduction | 1 |
Intrafirm Transactions in a Corporate Environment | 3 | |
Megatrends and the Significance of Intrafirm Transactions in International Trade | 5 | |
The Need for a Multidisciplinary Approach | 11 | |
Overview of the Book | 11 | |
2 | The New Tax Environment of Transfer Pricing - A U.S. Perspective | 17 |
Major Legislation and Regulations in the United States | 17 | |
Surveillance and Investigation of Transfer Pricing Practices | 19 | |
Recent Changes in Transfer Pricing Regulations | 21 | |
Some Audit Techniques Used by IRS Examiners | 28 | |
3 | New Transfer Pricing Regulations in Canada, Japan, South Korea, and the European Community | 33 |
The Importance of Transfer Pricing to Canada | 33 | |
Transfer Pricing Regulations in Canada | 37 | |
New Regulations in Japan | 39 | |
Rules and Regulations in South Korea | 41 | |
New Tax Directives and Conventions in the EC | 42 | |
4 | Research Methodology and Profile of Respondent Firms | 49 |
Current Literature on Transfer Pricing | 49 | |
Evaluation of Current Literature | 59 | |
Content of the Questionnaire | 60 | |
The Survey and Profile of the Respondent Firms | 60 | |
5 | Transfer Pricing Methods | 67 |
The Magnitude of Intracompany Transfers | 68 | |
The Extent of Usage of Transfer Prices | 68 | |
Pricing Methods for Intracompany Transactions | 69 | |
Company Size and the Orientation of Transfer Prices | 72 | |
Some Guidelines for Selecting Transfer Pricing Methods | 74 | |
6 | Environmental Variables of International Transfer Pricing | 81 |
The Stakeholders in International Transfer Pricing and Their Conflicting Interests | 81 | |
Prior Research on Environmental Variables | 83 | |
Responses by Multinational Firms - An Overview | 85 | |
Responses to the 1990 and 1977 Studies - A Comparison | 87 | |
Results from a Factor Analysis | 90 | |
7 | Other Issues and Conclusions | 99 |
Systems' Objectives and Policy Authority | 99 | |
How Policy Disagreements Were Resolved | 101 | |
Policies on Outside Purchases of Intermediate Goods | 103 | |
Implications from the Research | 104 | |
App. A: Survey Questionnaire | 109 | |
App. B: Section 482 of the Internal Revenue Code Allocation of Income and Deductions Among Taxpayers | 113 | |
App. C: Sections 69(1), 69(2), and 69(3) of the Canadian Income Tax Act of 1972 | 114 | |
App. D: Information Circular 87-2 of Revenue Canada, February 27, 1987, International Transfer Pricing and Other International Transactions | 116 | |
App. E: Sections 770 to 773 of the U.K. Income and Corporation Taxes Act of 1988 | 131 | |
Index | 139 |
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Add Transfer Pricing In The 1990s, Transfer pricing is a dynamic and multidimensional topic that has captured the attention of academicians, corporate executives, and tax authorities for many decades. The issues of transfer pricing are very complex and the stakes are extremely high because, Transfer Pricing In The 1990s to the inventory that you are selling on WonderClubX
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Add Transfer Pricing In The 1990s, Transfer pricing is a dynamic and multidimensional topic that has captured the attention of academicians, corporate executives, and tax authorities for many decades. The issues of transfer pricing are very complex and the stakes are extremely high because, Transfer Pricing In The 1990s to your collection on WonderClub |