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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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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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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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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2009 A REPORT ON TRANSFER PRICING – BENCHMARKING ANALYSIS PricewaterhouseCoopers Pvt Ltd By NAME Tax :- NEHA Services and RegulatoryAGARWAL (TRS) ENROLLMENT NO :- 08BS0001891 Transfer Pricing MOBILE NO :- 9830117116 Neha Agarwal 08BS0001891 //2009 Transfer Pricing study A REPORT ON TRANSFER PRICING – BENCHMARKING ANALYSIS By NAME: - NEHA AGARWAL ENROLLMENT NO:-08BS0001891 MOBILE NO:-+919830117116 A report submitted in partial fulfillment of the requirements of
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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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Quo vadis? Towards an 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
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A Case Study on Pricing Strategy Schwinn Bicycles J. Paul Peter (University of Wisconsin-Madison) Inside a plain brown building in Boulder‚ Colorado‚ is a shrine to an American icon; the Schwinn Bicycle. Some mud-caked from daily use‚ some shiny museum pieces – dozens of bikes stand atop file cabinets and lean against cubicles. Amid the spokes and handlebars‚ a group of zealots is working to pull off the turnaround of the century in the bike business. Brimming with energy‚ they are determined
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