Transfer Pricing

The role of multinational companies (MNEs) in international trade has become very great importance in the last 20 years. This is in large part to the increase in the integration of national economies and technological progress, in particular in the area of communication. The growing importance of MNEs develop complex issue of taxation on both the tax administration as well as MNEs, since the regulations of each country in the taxation of MNEs can be considered in isolation, but should be considered in the wider international importance (Grimwade, 2000).

The main topic of this research paper is taxation. Seeing that this topic is pretty open, I’ve chosen to write about the proposed idea of Fair Tax. Along with a little bit of insight on Fair Tax and a couple highlights of history, I’ll try and explain some pros and cons as well as give my opinion on the topic.

Today’s economy was founded upon the fundamentals of capitalism and continues to find its strength in the presence of freedom of enterprise and trade. Regulation and taxes are vital in order to support fairness amongst businesses and to provide funds for the government to develop and maintain the country’s infrastructure. Most companies distribute some of the company’s accumulated profits, so that is why it is important to characterize the distribution under whether it

Income tax is considered to be one of the greatest ways that a country amasses wealth through known means from the public in order to use the funds for the benefit and welfare of the community. Since a very long time, there have been many discussions and debates on the way the finds collected for income tax have been spend. There are many who think that there is a lot of mismanagement and feel that the amount of the actual money spent on welfare of the community is far less that what gets collected by the country.

Alabede, J. O., Ariffin, Z. B. Z., & Idris, K. M. (2011). Determinants of tax

Metlife, Inc. (“Metlife”, ”Company”) is a multinational insurance company which carries operations both in the U.S. and in various other foreign jurisdictions. The taxable income that Metlife generates abroad through its subsidiaries is subject to income tax under the laws of those foreign jurisdictions within which the income is derived from. Under the U.S. worldwide taxation system, that same income is also subject to U.S. tax upon (deemed) repatriation to Metlife. The apparent result of the above is the double taxation of the income earned abroad. In order to alleviate this issue, the U.S. makes available to the taxpayer a Foreign Tax Credit (“FTC”) for foreign income taxes paid, subject to certain limitations. The calculation of the FTC is a complex process which is comprised of many steps, most of which are beyond the scope of this memorandum. The only step that this memorandum is concerned with is the allocation/apportionment of expenses to

The US transfer pricing regulations, as outlined in Section 482 of the Internal Revenue Code, are similar to the Organization for Economic Co-operation and Development (OECD) guidelines. They have a commitment to the arm 's length principle, as do many other countries worldwide who use it as a basis for bilateral treaties between governments. US Guidelines say that in the case of any transfer of intangible property, the income shall be proportionate with the income resulting from that intangible property. They insist companies provide documentation of a reasonable calculation for its transfer price and the burden to prove the calculation inaccurate is not on the IRS. The US guidelines also authorize the IRS to reallocate income, deductions, and other tax items between controlled taxpayers when necessary “to prevent evasion of taxes” or to “clearly reflect income”. (26 CFR §1.482)

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Related to the transfer process described by Freud (transferring unresolved conflicts in childhood to the therapist), a concept currently extended to include the transfer of feelings and behavioral patterns not only from children's conflicts with parents, but also with other significant persons In the course of life. While client and therapist focus their attention on client issues and issues, there is an interpersonal process in which clients behave with the therapist the way they have learned to do it with other meaningful people in their lives. The therapist's task is to avoid responding to clients in a predictive way, so that the client experiences a new and more satisfactory response in his relationship with the therapist.

Each individual pays income taxes when they receive enough wages, and they also pay sales taxes when they purchase for goods. There are diverse kinds of taxes which are should be paid by both sellers and buyers. Many politicians of a country greatly consider the fairness of paying taxes to receive high attention (206). The fairness of taxing based on the ideal tax system which is fair, equivalent and clear to all taxpayers. There are two conflicting principles of fairness of taxes; one is the benefits principle and another is the ability-to-pay principle.

Compare and contrast the taxation system between Australia and Bangladesh and discuss which system is more effective. The essay should also focus on the effectiveness of double taxation treaties of these two jurisdictions.

I’ve summed up the introduction of Taxation to these slight words. Taxation is defined as a way that the government able to generate or collect revenue from the citizen of one’s nation through different sources. As what I’ve learned from Taxation course that there are two types of taxation, direct which are paid by the taxpayer directly to the government, and indirect which are collected by an intermediary (like a retail store) from the consumer. The intermediary who will file the tax return later and forward the amount of the money to the government with the return. This tax is applicable to organizations and individuals. In this reflection, I would like to highlight what I learned of business and individual taxation, the experience on working with a group for the project and what challenges I faced and how I was able to get past.

Transfer pricing is one of the key factors of a management control system, which helps a company to achieve its goals, including profit maximization and tax minimization.

The objective of International Accounting Standard 12 is to advise on the accounting treatment for income taxes. The main issue in accounting for income taxes is how to account for the current and future tax consequences of certain items. One item it advises on is the future recovery or settlement of the carrying amount of assets or liabilities that are recognized in an entity’s statement of financial position. The second main item the standard covers is transactions and other events of the current

During the contemporary tax scenario, where the trade and investment barriers have been totally dismantled and there is huge inflow of foreign capital in almost every sector of the economy, the need for Direct Tax Avoidance Agreements (‘DTAAs’) is rising day by day. Owing to the special nature and scope of these DTAAs [which can also be mentioned as Direct tax Treaties (‘DTT’) or Direct Tax Conventions (‘DTC’)] the professionals, who have to deal with these provisions on a regular basis, and provide professional advice to their clients seldom face a problem as these DTAAs have two very different purposes which have to be harmonised, they are; curtailing of or curbing of economic double taxation as against each and every State’s appetite for more tax revenues.