The distinctive chara transfer pricing: a complex issue ch 3- a company in country a boug sec 33 international transfer pricingcorporation-tax authorities might judge a compa transfer pricing: a complex issue ch 3comparable uncontrolled price metho dissertation. Doctor of philosophy department of economics university of toronto 2010 this thesis examines the income-shifting behaviour of multinational corporations when professor mintz had been on my phd committee till he left the university of toronto to 344 non-arm's length transactions and transfer pricing rules. Transfer pricing is a long-standing problem, and the research of such problem is for a long timeearly in the 40s-50s of last century, people toke the problem of transfer pricing seriously ,gradually. Oddleif is a tax lawyer (phd), with transfer pricing being his field of specialization he also holds an msc in accounting and auditing from nhh his phd thesis “ arm's length distribution of operating profits from intangible value chains” is a study of how multinational enterprises are obliged, pursuant to the oecd and us. Managing international transfer pricing policies: a grounded theory study elliott, jamie (1999) managing international transfer pricing policies: a grounded theory study phd thesis, university of glasgow full text available as:. Application of transfer pricing - efficiency and taxation university of stavanger stavanger, spring 2010 author: ann tonje helland masterthesis in industrial economics, university of stavanger teaching supervisor: frank asche, professor, university of stavanger. Senior lawyer, phd oddleif is a senior lawyer in the firm's tax department he holds a doctoral degree in international tax law from the university of bergen on the the thesis deals with a range of key issues in international tax law transfer pricing related to intangible assets is a priority area for tax authorities worldwide,. Transfer pricing transfer prices are the monetary values attaching to internal transactions between divisions of a company and can be defined in both a narrow and a broader sense foreign tax regulations) into the transfer pricing problem accounting context, unpublished phd thesis, illinois university 1977, p.
Transfer pricing rules at panama's tax administration he is also a 2016 phd in law candidate at dauphine university jose's phd thesis emphasizes transfer pricing approaches concerning the oil industry as an advisor, he dictates the module “arm's length principle and transfer pricing methods” for ciat and coordinates. He also said the un model tax treaty's commentary to article 9 will be updated in 2017 to make it consistent with oecd transfer pricing work on intangibles the un and i am a phd student writing a thesis on transfer pricing issues and have really learnt a lot from your discussions keep up the great work. Second, i intended to write a phd thesis on international taxation to spend more time on this research area achieving my second goal is the present doctoral dissertation i would like to thank my 1the manipulation of transfer prices as well as proﬁt- and debt-shifting across countries are popular strategies of tax.
Needless to say, this thesis will focus primarily on the pressure area of transfer pricing inspired by the illustrious world of international tax planning and the increased public awareness on tax avoidance, this study tries to examine the effect of taxation on profit shifting behavior by us-based mnes the following research. Kyrylo kasianok, phd student, kyiv national university of trade and the objective of the article is the disclosure of the transfer pricing essence and justification of the neces- sity for efficient tax control of transfer thesis while defining concept of transfer pricing and its implication in the world and in. Research has been undertaken to analyse the degree to which transfer pricing can be used to effectively influence managerial international transfer pricing in a developing economy context: perspectives from the tax payers and the tax authorities phd dissertation lingnan university hong kong [online] available at.
Tax evasion, tax avoidance and tax expenditures in developing countries: a review of the literature, 2009, prepared for the uk department for international development (dfid) (joint with clemens fuest) essays on the taxation of multinational firms, 2008, phd thesis, university of munich transfer pricing laws , cesifo. Transfer pricing advisors he has a ba in commerce from the university of bombay and qualified as a chartered accountant in 1985 isabel calich (brazil) holds a phd from the london school of economics and political science (lse) her lse phd thesis examines the relationship between international taxation and. Transfer pricing rules in the brics world: a shifting balance in global taxation governance thassiane ayres gossler the university of western ontario supervisor chios carmody the university of western ontario co-supervisor colin campbell the university of western ontario graduate program in law a thesis.
Tinbergen magazine 13, spring 2006 letters from alumni life after the phd thesis defense transfer pricing is a multidisciplinary subject occupying the time and talents of (tax) lawyers, accountants and economists you basically provide advice to multinational enterprises in determining arm's length transfer prices from a tax.
Christian possesses significant technical competences and is broadly respected for his knowledge within transfer pricing in 2011 he successfully defended a phd thesis on transfer pricing professional experience 2013-2014: visiting research scholar, university of hawaii, usa 2011-: assistant professor, copenhagen. Office, on the taxation of the resulting permanent establishments, and on anti- avoidance rules transfer pricing and state aid aspects are only investigated to the extent of their immediate corporation tax effect the subject of the doctoral thesis is limited to the corporation tax effects of cross-border mergers, other tax types and. The prize was awarded for her master's thesis titled “transfer-pricing rules and [more] dr marta castelon, a former research associate at the max planck institute for tax law and public finance, was honoured with a prize for her phd thesis international taxation of income from services under double tax conventions. Item type: thesis or dissertation (phd) subjects: h social sciences hd industries land use labor library of congress subject headings (lcsh):, international business enterprises -- egypt, transfer pricing -- egypt, profit- sharing -- egypt, egypt -- economic conditions official date: february 1992 dates:.