Internprissättningsproblematiken i ljuset av förslaget om hemlandsbeskattning för europeiska koncerner
Independent thesis Advanced level (degree of Magister)Student thesisAlternative title
The Issue of Transfer Pricing in the Light of the Proposal for Home State Taxation (English)
Throughout this thesis three main factors have been identified that can be out of significance for transfer pricing in multinational companies if the proposal for Home State Taxation is adopted. These factors are rules for calculation of the tax base, rules for dividing costs over periods and the tax rate. The formula for sharing profits will also become a factor that can have an impact on the European companies'incentives for transfer pricing interacting with above-mentioned factors. The effects of transfer pricing aiming at reducing the total amount of the taxation burden for a group of companies will be strongly reduced in the future if the proposal is adopted. Incentives for transfer pricing will loose importance, though not disappear altogether. Nevertheless new incentives to evade the rules may arise, especially in terms of careful choices concerning the establishment of every company in the group. The most positive effect of the proposal will probably be that the uncertainty of determining which transfer pricing rules apply will disappear, as only the system of rules of one country will be used for the calculation of the base for taxation. The double taxation, which has caused problems in the past since different rules for transfer pricing gave been applied, will disappear resulting in less costs for companies.
Place, publisher, year, edition, pages
Ekonomiska institutionen , 2002. , 53 p.
Master Thesis in Business Administration (Magisteruppsats från Ekonomprogrammet), 2002:20
Law, transfer pricing, Home State Taxation, harmonisation, direct taxation
IdentifiersURN: urn:nbn:se:liu:diva-1371OAI: oai:DiVA.org:liu-1371DiVA: diva2:18694