Western Regional Chapter of International Fiscal Association –Indian Branch Transfer Pricing Problems‚ Strategies and Documentation Recent International Case Law on Transfer Pricing by Nishith Desai The Taj Mahal Hotel‚ Mumbai January 21st & 22nd 2002 Nishith Desai Associates 2 TRANSFER PRICING Content I. II. Introduction History III. Select International cases US Cases 1. 2. 3. Compaq Computer Corporation V. Commissioner DHL Corporation and Subsidiaries V. Commissioner Texaco
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Eagle Airlines Keith Russell‚ president of Eagle Airlines‚ a small airline operating in south-eastern Australia‚ had been considering expanding his operation and now the opportunity was available. An acquaintance had put him in contact with the president of a small airline in the west that was selling an aeroplane. Many aspects of the situation needed to be considered however‚ and Keith was having a hard time sorting them out. The Company Eagle Airlines (“Eagle”) owned and operated three
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hil61217_ch20_case.qxd 5/12/04 17:17 Page 46 ADDITIONAL CASES ■ CASE 20.3 PLANNING PLANERS This was the first time that Carl Schilling had been summoned to meet with the bigwigs in the fancy executive offices upstairs. And he hopes it will be the last time. Carl doesn’t like the pressure. He has had enough pressure just dealing with all the problems he has been encountering as the foreman of the planer department on the factory floor. What a nightmare this last month has been! Fortunately
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A case study of Virgin Airlines Introduction Internationalization of the business nowadays apparently became a trend for the organizations to expand their market position and gain the competitive advantage among their contemporaries. The extent and nature of business activities are almost as diverse and comprehensive as the totality of the social and economic interest of a man. Various business activities acknowledged the opportunities that the internationalization may deliver. Through their
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1. What role has leadership played in the success of Southwest Airlines? In an era where all the major players in the U.S. airline industry experienced problems‚ only Southwest Airlines remained profitable throughout that period. This amazing and continued success is attributed to its great leader Herb Kelleher. He has been a very successful leader who knows the employees and marketplace well and can effectively take action for the success of the organization. He applies flexibly to the growth
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Pricing Decisions are decisions faced by top management and marketing managers. How much to charge for a product or service depends on a multitude of factors such as competition‚ cost‚ advertising‚ and sales promotion. Economic theory suggests that the best price for a product or service is the one that maximizes the difference between total revenue and total costs. However‚ in reality‚ the price charged is usually some form of cost-plus‚ which is later adjusted for market conditions and competition
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Pricing is one of the most important elements of the marketing mix as it is the only mix‚ which generates a turnover for the organization; the remaining 3p’s are the variable cost for the organization. It costs to produce and design a product; it costs to distribute a product and costs to promote it. Price must support these elements of the mix. Pricing is difficult and must reflect supply and demand relationship (Constantinides‚ 2006). Pricing a product too high or too low could mean a loss of sales
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At the onset of the airline industry in the United States‚ major network airlines were the sole providers of air travel. This multifaceted industry was a difficult industry to break into as a consequence of “sophisticated customer segmentation‚ hub-and spoke models and costly information systems for reservations‚ fare wars and intense competition” (Thompson 2008). Shrinkage in airline ticket prices augmented the demand for airline travel. Many markets were simply deserted or over-looked by major
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to a specific environment. This is indeed the case with its implementation of its pricing strategy‚ which is one of localisation rather than globalisation. Table II illustrates the comparative Big Mac prices (flagship brand of McDonald’s) from around the world. It succeeds in highlighting the point that McDonald’s has had to come up with different pricing strategies for different countries. More importantly‚ rather than just having a different pricing policy for the Big Mac in these listed countries
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Table of Contents 1. The Need for Pricing 2. Pricing Software Industry Products 3. Licensing 4. Pricing Discrimination 5. Bundling 6. Other Pricing Issues 7. Summary The Need for Pricing Pricing has far reaching effects beyond the cost of the product. Pricing is just as much a positioning statement as a definition of the cost to buy. Price defines the entry threshold: who your buyers are and their sensitivities‚ which competitors you will encounter‚ who you will
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