The Fuqua School of Business Duke University International Strategy: WBA 434 Professors Heath‚ Huddart‚ & Slotta Transfer Pricing 1. Overview An essential feature of decentralized firms is responsibility centers (e.g.‚ cost-‚ profit-‚ revenue-‚ or investment-centers). The performance of these responsibility centers is evaluated on the basis of various accounting numbers‚ such as standard cost‚ divisional profit‚ or return on investment (as well as on the basis of other non-accounting measures‚ like
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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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Transfer Pricing in Developing Countries An Introduction Topics 1. Abstract 2. International tax law & its sources 3. Brief history of International Tax Law 4. Who gets the pie? 5. Arm ’s length principle : Cornerstone of International Tax Law 6. Transfer pricing methods 7. Problems with of source taxation of MNE ’s 8. Internet & e-commerce : Achilles heel of current International taxation regime? 9. Formulary Apportionment (FA) 10. Existing uses of Formulary Apportionment systems in the world
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delicious in many ways. Marketing & Pricing Stratergy:- The Indian noodles market is growing at a rate of 20 % annually and market can be penetrated by adopting the advertising /promotion strategy and also by setting up a strong distribution network. Price is the amount of money which is paid by the customer to the seller which varies on different distribution channels.When we detemine the price of Indomie in India‚some factors will impact the pricing such as the market share‚number of competitors
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BUSINESS MACHINES (IBM) 2 IMPORTANCE OF HISTORY IN MANAGEMENT 3 THE IMPORTANCE OF TECHNOLOGY IN ECONOMIC DEVELOPMENT 4 JOHN AKERS WAS A PRACTITIONER OF SCIENTIFIC MANAGEMENT 5 HOW BUREAUCRACY IN IBM RESULTED TO INEFFICIENCY 7 HENRI FAYOL’S PHILOSOPHY 10 THE MAIN LEADERSHIP PROBLEMS IN IBM 13 OTHER MANAGEMENT ISSUES/LESSONS IN THE CASE 15 SIMILAR CASE – UCHUMI SUPERMARKET 16 SUMMARY OF INTERNATIONAL BUSINESS MACHINES (IBM) In the early 1900s
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ACKNOWLEDGEMENT In this assignment‚ we would like to take an opportunity to send our appreciation to the college due to a proper syllabus and good environment have been provided. Next‚ we would like to thank our Costing and Pricing lecturer‚ Mr.Balan for his generous help. We believe that we cannot create an excellent assignment without his advice and help. At the same time‚ we would like to express our thanks to those who helped us to carry this assignment successfully. Thank you very much
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customers) - Right investment to S/360 - Success of PC - Great reputation -> attract top talent Factors led to its problems during the late 1980 and earry1990s: - Did not keep in touch with customers - Didn’t understand market need (fewer purchase IBM mainframes) - Marketing effort missed the mark - Turf battles between autonomous divisions - Spending too much on fixed cost (building‚ data processing cost‚ ..) - Management IT problems such as poor internal IT problems - Products complexity and
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Chapter 1 Introduction of the Topic TRANSFER PRICING TRANSFER PRICING is a term used to describe all aspects of inter Company pricing arrangements between related business entities‚ and commonly applies to inter Company transfers of tangible and intangible property. Inter Company transactions across borders are growing rapidly and are becoming much more complex. Transfer pricing refers to the internal pricing system that is used when divisions in the same firm deliver products or services
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Executive Summary IBM and Accenture are both huge companies and uses five factor DuPont analysis to achieve a return on equity. IBM has a higher return on equity than Accenture‚ and therefore the management are more efficient in generating shareholder value per dollar invested. However both the companies are performing better than the industry average. IBM does also take lesser number of days to convert cash on hand compared to Accenture and industry average. But‚ Accenture is taking more days
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7 Transfer Pricing LEARNING OBJECTIVES : After studying this chapter students will understand. * Purpose of transfer pricing * Responsibility of a division as responsibility centre * Conflicts between the divisions * Setting of transfer price where the profit of the organisation can be higher. 7.1 Introduction The whole organisation can be divided into a number of divisions‚ the performance of each division can be measured in terms of both the income earned and the
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