Traduction de «transfer price » (Anglais → Français) :

transfer price | intercompany price | intercompany transfer price | intra-group price

international taxation of a transfer price | international taxing of a transfer price | international taxation of transfer prices | overseas taxation of transfer prices

EU Joint Transfer Pricing Forum | EU Joint Transfer Pricing Forum expert group | expert group on transfer pricing | JTPF [Abbr.]

OECD Transfer Pricing Guidelines | OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

intra-company pricing | transfer pricing

organise the transfer of a healthcare patient | set up plans related to the transfer of care | develop plans related to the transfer of care | organize the transfer of a healthcare patient

perform liquid goods transfers | transfer pipeline liquids | transfer liquid goods | transfer liquid material

45. Notes also the efforts made through the creation of the Platform for Tax Good Governance, which brings various stakeholders around the same table with the aim of creating consensus around the issue of tax avoidance, in particular in an international context, and the Joint Transfer Pricing Forum, which issues a number of guidelines on the technical issues surrounding transfer pricing; stresses that, to date, these bodies have contributed to making limited corrections to the corporate tax framework; regrets that the guidelines issued by the Joint Transfer Pricing F ...[+++]orum so far have not sufficiently tackled the issue of tax avoidance; deplores the fact that the composition of the Joint Transfer Pricing Forum, despite a recent update of its membership, is still unbalanced; objects, moreover, to the fact that tax experts contribute to the work on guidelines on transfer pricing while, at the same time, they may be advising their clients on aggressive tax planning strategies based on transfer pricing, and thus be in a position of conflict of interest;

45. Notes also the efforts made through the creation of the Platform for Tax Good Governance, which brings various stakeholders around the same table with the aim of creating consensus around the issue of tax avoidance, in particular in an international context, and the Joint Transfer Pricing Forum, which issues a number of guidelines on the technical issues surrounding transfer pricing; stresses that, to date, these bodies have contributed to making limited corrections to the corporate tax framework; regrets that the guidelines issued by the Joint Transfer Pricing F ...[+++]orum so far have not sufficiently tackled the issue of tax avoidance; deplores the fact that the composition of the Joint Transfer Pricing Forum, despite a recent update of its membership, is still unbalanced; objects, moreover, to the fact that tax experts contribute to the work on guidelines on transfer pricing while, at the same time, they may be advising their clients on aggressive tax planning strategies based on transfer pricing, and thus be in a position of conflict of interest;

29. Notes that the existing guidelines for transfer pricing leave MNCs a significant margin of discretion in the choice and implementation of evaluation methods; stresses that the lack of any effective common standard for transfer pricing and the various derogations, exceptions and alternatives provided for are being exploited by MNCs, in contradiction with the spirit of those guidelines, to calibrate their taxable profits by jurisdiction and reduce their overall tax liability through, for instance, abusive cost-plus, arbitrary setting of profit margins or the questionable exclusion of certain expenditure from their calculation; stress ...[+++]es that the best way to address the issue of transfer pricing at EU level is through common tax base consolidation, which does away with the need for these prices;

29. Notes that the existing guidelines for transfer pricing leave MNCs a significant margin of discretion in the choice and implementation of evaluation methods; stresses that the lack of any effective common standard for transfer pricing and the various derogations, exceptions and alternatives provided for are being exploited by MNCs, in contradiction with the spirit of those guidelines, to calibrate their taxable profits by jurisdiction and reduce their overall tax liability through, for instance, abusive cost-plus, arbitrary setting of profit margins or the questionable exclusion of certain expenditure from their calculation; stress ...[+++]es that the best way to address the issue of transfer pricing at EU level is through common tax base consolidation, which does away with the need for these prices;