Sökning: "formulary apportionment"
Hittade 4 uppsatser innehållade orden formulary apportionment.
1. Profit-allocation based on value creation in the digital economy
Magister-uppsats, Lunds universitet/Institutionen för handelsrättSammanfattning : With the proposed Directive by the European Commission to tax the digital economy more effective by introducing a digital permanent establishment, the question raises how to effectively tax it. Under the current profit-allocation principles, profits are allocated to the jurisdiction in which the significant people functions are situated. LÄS MER
2. The Allocation of Residual Profits Deriving from Intangibles in a Transfer Pricing Context
Magister-uppsats, Lunds universitet/Institutionen för handelsrättSammanfattning : After giving an introduction to the basics of transfer pricing with a focus on intangibles, this paper aims to establish the nature of residual profits and what needs to be considered when such profits are generated. It will become clear that residual profits are an economic concept rather than an element of tax law which is why, first, a connecting link needs to be found between these two disciplines. LÄS MER
3. Formulary Apportionment in the European Union
Uppsats för yrkesexamina på avancerad nivå, Lunds universitet/Juridiska institutionenSammanfattning : The European Union has discussed the idea of a potential shift from a system of dividing the EU source income of multinational companies based on separate accounting and the arm's length principle, to one based on consolidated base taxation with formulary apportionment. EU businesses have for several years highlighted numerous tax obstacles in the EU that prevent them from operating on the basis consistent with the Single Market. LÄS MER
4. Formulary Apportionment - a realistic alternative to the arm's length principle within the EU?
Uppsats för yrkesexamina på avancerad nivå, Lunds universitet/Juridiska institutionenSammanfattning : The international accepted standard today, which is used for tax purposes to attribute profits between related enterprises operating in different countries, is the so-called arm's length principle. The arm's length principle states that transfer prices between related enterprises have to be the same amount as transfer prices in comparable transactions between unrelated enterprises. LÄS MER