Record Details

IMPACT OF TRANSFER PRICING DECISIONS ON THE GENERAL CORPORATE RESTRUCTURING DRIVES

Scholedge International Journal of Business Policy & Governance

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Field Value
 
Title IMPACT OF TRANSFER PRICING DECISIONS ON THE GENERAL CORPORATE RESTRUCTURING DRIVES
 
Creator Gemawat, Lokesh
 
Subject —
Transfer Pricing, Cross border transaction, International Trade, International Business
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Description A business restructuring might involve cross-border transfers of one thing important, e.g. of valuable intangibles, though this is often not continuously the case. It’s going to additionally or as an alternative involve the termination or substantial renegotiation of existing arrangements, e.g. producing arrangements, distribution arrangements, licenses, service agreements, etc. Under Article nine of the OECD Model Tax Convention, wherever the conditions created or obligatory in a very transfer of functions, assets and/or risks, and/or within the termination or renegotiation of a written agreement relationship between 2 associated enterprises placed in 2 disagreement countries differ from people who would be created or obligatory between freelance enterprises, then any profits which might, except for those conditions, have accumulated to at least one of the enterprises, but, by reason of these conditions, haven't therefore accrued, could also be enclosed within the profits of that enterprise and taxed consequently.
 
Publisher Scholedge R&D Center
 
Contributor —
 
Date 2015-06-25
 
Type info:eu-repo/semantics/article
info:eu-repo/semantics/publishedVersion
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Format application/pdf
text/html
 
Identifier http://thescholedge.org/index.php/sijbpg/article/view/155
 
Source Scholedge International Journal of Business Policy & Governance ISSN 2394-3351; Vol 2, No 5 (2015); 14-20
2394-3351
 
Language eng
 
Relation http://thescholedge.org/index.php/sijbpg/article/view/155/127
http://thescholedge.org/index.php/sijbpg/article/view/155/135
http://thescholedge.org/index.php/sijbpg/article/view/155/182
 
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Rights Copyright (c) 2015 Scholedge International Journal of Business Policy & Governance ISSN 2394-3351
http://creativecommons.org/licenses/by-nc/4.0