subsidiary that in term of raw material or even product itself. Beyond on that sale will be happen‚ however the sale price might be not at normally or independent sale like to the unrelated customer or company. This will cause sale price that much lower than unrelated company. From this transfer pricing will be occurring. This will cause minimize in the group tax liability. Transfer pricing is the one that can be used to reduce tax liability. It is the way of tax avoidant. Tax avoidance is the deliberate
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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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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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Case 1 Atlantic Corporation Maastricht University School of Business and Economics Corporate Governance and Restructuring 1. Is the acquisition of Royal’s linerboard mill and box plants a sound strategic move? Consider the short- as well as long-term outlook for linerboard prices and the profitability of the linerboard industry. Furthermore‚ what basis‚ if any‚ is there for expecting AtlanticRoyal’s combined linerboard and box mill operations to do better/worse than the industry overall?
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Case: Fisher-Price Toys‚ Inc. 1. Basic information 1) 2) Company: Fisher-Price Toys‚ Inc. (Industry: Child toys) Business dilemma: a rash marketing decision has to be made on carrying out whether a new quality product (product name: ATV Explorer) at exceptional high price or a new less-quality product at moderate price 2. Business dilemma 1) Key problem: (1) price-point: Cost for a projected toy can’t be made within budget‚ resulting in a much higher price ($18.5) than planned. High price disobeys
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MAC Development Corporation The McCaffreys are in a sticky situation as they have tied up land for a development project and everything seems to be falling apart. They have deadlines to meet and so many moving pieces that I had to read the Case Study several times to wrap my head around it all. At the start of the Phoenix project‚ there were basically three main puzzle pieces the McCaffreys had to juggle. The first one was the Village of Woodland‚ where the land was located‚ had verbally
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General Electric Case Analysis Case Recap General Electric‚ (GE)‚ is a diversified technology and financial services corporation that has a history of tremendous success. The company’s name is well known across the United States and is recognized by consumers as the “practical innovator” (Crystal & Herskovitz‚ 2010). In order to continue its achievements‚ GE’s strategy is to focus its resources in new product innovation and comprehensive brand positioning. It has created the “Profile” and
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HRM Issues/Diversification Strategies Jamaine Williams Instructor Dr. Hogan Bus599 February 29‚ 2012 Abstract In this paper‚ I will present an analysis of Nucor Corporation. The paper will discuss the trends in the steel industry and how it may impact Nucor’s strategy‚ Discuss the organizational structure and management philosophy at Nucor‚ Identify three (3) HRM issues related to strategy implementation and recommend actions to address these issues‚ Based on the situation‚ recommend
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Case Study: Enron Corporation Accounting Scandal 1. What is Enron Scandal? Formed in 1985 from a merger of Houston Natural Gas and Internorth‚ Enron Corp. was the first nationwide natural gas pipeline network. Over time‚ the firm’s business focus shifted from the regulated transportation of natural gas to unregulated energy trading markets. The guiding principle seems to have been that there was more money to be made in buying and selling financial contracts linked to the value of energy
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[pic] By: Michael Malone Statement of the Problem Rajat Singh‚ a managing director at Hudson Bancorp‚ needs to find a way to rejuvenate the paper check corporation. One main part that needs to be calculated is the appropriate mixture of debt and equity for the firm. The company needs to determine the correct mixture so that they can both minimize the cost of capital and increase the shareholders value. I will analyze the current and future situation of the company‚ trying to find the correct
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