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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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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General Electric (GE) Strategic Management Case Study: General Electric (GE) Analysis using Porter’s Approach By: Johnny Cantrell Part A: General Electric‚ or GE as it is better known‚ is a diversified technology‚ media‚ and financial services company. Their primary objective as stated is “focused on solving some of the world’s toughest problems”. Their slogan‚ which is “imagination at work”‚ truly says everything there is to know about the vision of the company. Inside
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which was purchased by its customer. For a majority of products price is determined in a free market by the forces of supply and demand. Also price is one of the 4 elements of Marketing Mix. Pricing strategies are only the medium or long-term pricing plans that a business adopts. There are some main pricing strategies: Price skimming is often used when a new innovative product is launched onto the market. The risk that this product will face competition in the short term is very low. So by setting
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Case Study Report McDonald ’s BACKGROUND: Brothers Richard and Maurice McDonald founders of McDonald ’s Corporation grew from a single drive-in restaurant in San Bernardino‚ California in 1948 to the largest food service organization in the world. In 1955 Ray Kroc opened firs McDonald ’s in Des Plaines‚ Illinois and became exclusive franchising agent for the company. By 1991 McDonald ’s owned $13 billion of fast-food industry‚ operating 12‚400 restaurants in 59 countries (Ezine). The company
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management experience. The last benefit of this model is the chance of the company to identify and develop the locations‚ polices quality‚ and develops new products. Operations are large scale and efficient. Weaknesses of McDonald’s model Sharing profits McDonald and the franchisee seek to earn profits over a long period of time so the revenues must be fixed and sufficient to share profits among them. Loss of absolute control MacDonald doesn’t have the complete right to manage or take decisions alone. So
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ID 310973 Contact Details: Contact Person Address Telephone No. Fax No. Email Mr. Tan Hwa Seong 3 Jalan Datuk Sulaiman 2‚ TTDI‚ 6000 Kuala Lumpur Malaysia +60 122862816 +60 377107300 roysten.tan@gmail.com STRATEGIC BUSINESS ANALYSIS MCDONALD ’S CASE STUDY Table of Contents EXECUTIVE OVERVIEW............................................................................................. I-4 TASK I. 2003 SWOT ANALYSIS....................................................................
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With India’s business environment showing potential for growth in the early 90s due to economic liberalization‚ population and income growth‚ MacDonald’s (MD) has adopted an international strategy by tapping into the market in India to expand their business. MD relative success has come from their willingness to ‘think global‚ act local’ in its transnational strategy‚ taking India’s macro-environment into consideration in carrying out their business. The 4 factors are as follow: Firstly‚ the main
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PRICING METHODOLOGY Pricing methods adopted by an organization determines the values attached to its products. Pricing determinant can be Internal or External. An Internal pricing determinant is one that is controlled by the marketer while the external is not controllable by the marketer. We shall be considering the following types of pricing models: PRICE DISCRIMINATION: Price discrimination is the practice of setting a different price for the same product in different segments to the market.
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KFC (Kentucky Fried Chicken) INTRODUCTION: KFC is a fast food restaurant chain headquartered in Louisville‚ Kentucky‚ United States‚ which specializes in fried chicken. An "American icon"‚ it is the world’s largest fried chicken chain and the second largest restaurant chain overall after McDonald’s‚ with over 17‚000 outlets in 105 countries and territories as of December 2011. KFC was founded by Harland Sanders‚ who began selling fried chicken from his roadside restaurant in Corbin‚ Kentucky during
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