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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fully understand and impossible for them to fully control’ (The Times‚ n.d. p1). Virgin Atlantic is an international airline that is based in the UK. It was started by the entrepreneur Richard Branson in 1982 and now flies to 30 destinations around the world (Virgin Atlantic Airways Ltd‚ 2011). By looking at the PEST forces of Virgin’s external environment‚ the aim is to see how these influence the airline and how Virgin can use this information to their advantage. Two main political factors in Virgin’s
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The Viability of Mobile Applications as a Marketing Tool Introduction and Definition Mobile applications are software that run on Smartphones with the purpose of adding value to consumers smartphones‚ by increasing their phones functionality. Traditionally mobile applications were distributed with the intensions of acquiring direct revenue from either incorporating advertisements on the applications through the use of banners‚ or charging a download fee. In recent years the viability for apps to
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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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2 million users. „I-Mode’s” Business model „I-mode” has been extraordinarily successful in Japan. This is because of its outstanding convenience and it’s unique business model. Its reliance on this system offers an innovative approach to the mobile service value chain and to wireless service / Internet relationships. Exists close cooperation with equipment manufacturers‚ content providers‚ and other platforms to ensure that wireless technology‚ content quality‚ and user experience evolve
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Pricing productsIntroduction Products and services have a price just as they have a value. Many non-profit and all profit-making organizations must also set prices. Pricing is controversial and goes by many names: Price is all around us. You pay rent for your apartment‚ tuition for your education. The airline‚ railway‚ taxi and bus companies charge you a/are; the local utilities call their price a rate; and the local bank charges you interest for the money you borrow ; the guest lecturer charges
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Pricing Decisions are decisions faced by top management and marketing managers. How much to charge for a product or service depends on a multitude of factors such as competition‚ cost‚ advertising‚ and sales promotion. Economic theory suggests that the best price for a product or service is the one that maximizes the difference between total revenue and total costs. However‚ in reality‚ the price charged is usually some form of cost-plus‚ which is later adjusted for market conditions and competition
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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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discussion of adopting transfer pricing regime in Bangladesh and needed initiatives for it. In this regard it is necessary first to develop clear perception about the concepts related with the issue. Keeping in view this need this section consists of review of the literature that is focused on how to adopt transfer pricing regime in Bangladesh‚ what initiatives to follow to adopting transfer pricing regime. The section further unfolds the impacts of transfer pricing regime in Bangladesh and then discusses
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1. Introduction Virgin Group is the use of Virgin as a brand name and a number of enterprises Group; it is one of the UK’s largest private companies that founded by famous British businessman Richard Branson. The Group business start with music business‚ now it develops includes tourism‚ aviation‚ and entertainment and so on. Richard Branson holds the control power over the brand Virgin‚ but its subordinate institutions are different and complicated. Each of the virgin group company is independent
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