Traduction de «prix du transfert de l'actif » (Français → Anglais) :

price at which the asset is transferred

advance pricing agreement | advance pricing arrangement | APA [Abbr.]

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

Animal Industries Award in Extension and Public Service

give legal legitimacy to the transfer of assets | providing legal legitimacy to the transfer of assets | provide legal legitimacy to the transfer of asset | provide legal legitimacy to the transfer of assets

inter-company transfer price

transfer cost | transfer price

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

The transfer pricing rules are used to attribute the profit of multinational groups to the different countries based on an analysis of the functions, assets and risks within the value chain of the group.

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 Forum 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;

22. Takes the view that national preferential regimes and the poor level of coordination or convergence between the Member States’ tax systems, despite the effective economic interconnections and interplay within the internal market, result in a number of mismatches that allow aggressive tax planning, double deductions and double non‑taxation, for instance through one or a combination of the following practices: abusive transfer pricing, locating deductions in high-tax jurisdictions, passing on funds raised by loans through conduit companies, risk transfer, hybrid financial products, exploiting mismatches, tax arbitrage, royalty agreemen ...[+++]ts, treaty shopping, and locating asset sales in low-tax jurisdictions;

(48)'asset separation tool' means the transfer by a resolution authority exercising the transfer powers of assets and rights of an institution that meets the conditions for resolution to an asset management vehicle in accordance with Article 36.