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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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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Marketing Management Psychological Pricing Rodrigo Fernández-Romero. 20th March 2010. Psychological Pricing Many sellers believe that prices should end in an odd number (9‚99€) instead of 10€ as price. Why?. • • • Because consumers have the tendency of ignoring the last digits instead of doing the rounding. Although actually seeing the cents‚ they may subconsciously ignore them. Some suggest that this effect may be enhanced when the cents are printed smaller (for example‚ €19.99)
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MANAGING TRANSFER PRICING Sarbanes-Oxley requires a company to establish that it has internal controls to ensure accurate financial reporting and that the auditor attest to the assessment of those controls. An obvious concern for all multinationals after SOX is whether there are effective controls in place to deal with transfer pricing exposure. An increasingly important element of transfer pricing documentation relates to the influence of legislation‚ ethical standards‚ and associated matters
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effective predatory pricing provision Garth Campbell* The level of criticism directed at s 46 of the Trade Practices Act 1974 (Cth) for its inability to capture predatory pricing indicates that smaller businesses are extremely concerned about this practice. Such criticism reached its peak following the High Court’s decision in Boral Besser Masonry Ltd v ACCC (2003) 215 CLR 374‚ which rejected a claim of predatory pricing. Since then‚ the Birdsville Amendment and other recent amendments to s 46 have attempted
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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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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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Lecture 2: Pricing by Arbitrage Readings: Ingersoll – Chapter 2 Dybvig & Ross – “Arbitrage‚” New Palgrave entry Ross – “A Simple Approach to the Valuation of Risky Streams‚” Journal of Business‚ 1978 Here we will take a first look at a financial market using a simple state space model. We first develop some structure then examine the implications of the absence of arbitrage. Often in finance problems‚ uncertainty is characterized by the use of a set of random variables with a particular
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Cited: Bak‚ John S. “Escaping the Jaundiced Eye: Foucauldian Panopticism in Charlotte Perkins Gilman’s ‘The Yellow Wallpaper.’” Studies in Short Fiction 31.1 (Winter 1994): 39-46. Crewe‚ Jonathan. “Queering ‘The Yellow Wallpaper’? Charlotte Perkins Gilman and the
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When Who What 11/17/2004 Rob Seaman Original creation 11/22/2004 Ashish Kothari Updates 3/22/2006 Jonathan Fan Updates Table of Contents Revision History: 2 Table of Contents 3 What This Is 4 Whom to Contact 4 Dynamic Pricing Procedure 4 Steps 4 Step Details 7 1. Check Header Price List 7 2. Raise Expired Error 8 3. Raise Not Effective Error 8 4. Customizable Product Roll-Down 9 5. Get List Price 10 6. Get Root Price List Item Id 16 7. Split Unpriced Actions 17
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