Global Transfer Pricing - Free Essay Example

Sample details Pages: 2 Words: 645 Downloads: 8 Date added: 2017/09/21 Category Economics Essay Type Argumentative essay Tags: Development Essay Did you like this example? 1. Global Transfer Pricing: A Practical Guide for Managers , Ralph Drtina, Jane L. Reimers, S. A. M. Advanced Management Journal, v74n2, Spring 2009. Transfer Pricing Article Summary The authors give a beneficial guide for managers for selecting and implementing a transfer pricing policy. According to the article, transfer pricing are the amounts charged for goods and services exchanged between divisions of the same company. In a multinational company strict international tax laws regulate the amounts charged for goods and services, tangible or intangible, which cross borders. The article advises a company with operations in more than one country to be cautious when setting transfer prices for goods or services sold between divisions. The managers can learn from this article that methods traditionally used to set prices between divisions in a single country may not be acceptable for international tax purposes. The article addresses two major types of transactions, intra-c ompany sales of products and intra-company licensing of intangible property. A multinational company can maximize the profits by shifting profits from divisions in high-tax to divisions in low-tax jurisdictions countries. A description of how global transfer pricing works is given along with transfer pricing effect on taxable income. In this global economy, the trend for countries is to strengthen their effort to collect tax revenues from transfer pricing. A company can mitigate tax conflicts by negotiations and price agreements. The article describes the arms-length principles used by most countries and standardized by IRS S428 and by OECD (Organization for Economic Co-operation and Development) rule. The article indicates what challenges need to be resolved when applying these standards. Under the arm’s length principle one compares the remunerations from cross-border controlled transactions within multinationals with the remuneration from transactions made between in dependent enterprises in similar circumstances. The arms-length principle has become the international norm for allocating the tax bases of multinational enterprises among the countries where they operate. Five transfer pricing methods for finding arm’s length price are presented along with the comparability issues related to selecting the method and determining the transfer price. The article illustrates the arms-length principle applied for transfer pricing for intangible assets. These assets include intellectual property, patents, formulas, copyrights, trademarks, brand names, licenses, or software. The article show numeric examples of approved ways to calculate transfer prices and explain how application differs between tangible goods and intellectual property. The article concludes with a series of guidelines for managers on how to be aware of the complexity of transfer pricing and how to minimize the risk associated with multinational intra-company transfers. Ever y multinational company should have a documented transfer policy that guides managers’ actions. A company should continue to update its transfer price policy whenever changes to its business affect the factors used to establish the arm length principle. In addition a company with many cross-border transactions should consider an advanced pricing agreement to ensure tax dispute will be kept to minimum. In order to avoid significant cost or penalties to their multinationals companies, managers should become familiar with the regulations of the countries involved, for example using OECD and IRS resources. Analysis and Opinion This article expands the information about transfer pricing from textbook, and emphasizes the aspect of international transfer pricing. Given the global and sometimes controversial nature of transfer pricing, it is important to develop internationally shared principles, as the arm’s length principle, to help each country fight abusive transfer of profit abroad, while at the same time limiting the risk of double taxation of those profits. This article has a lot of applicability to my job, since I work in a multinational company, in projects that develop products across borders and involve transfer pricing. Intellectual property issues (e. g. , valuations) can have significant implications on an organization’s taxes and financial performance. The intangible assets, tax valuation of intellectual property and transfer pricing are highlighted by the article. Don’t waste time! Our writers will create an original "Global Transfer Pricing" essay for you Create order

Kashmir ; A lost paradise Essay - 3104 Words

Kashmir — a beautiful mountain state with clear rivers, evergreen forests and one of the highest death rates in the world. It is at the center of an age-old dispute between Pakistan and India that has dragged on from the independence of both nations over fifty years ago to the present time, with no resolution in sight. The combined population of the two nation totals over a billion, so no conflict between them is of passing importance, especially when nuclear weapons are involved. Pakistan and India share a common heritage, language, and traditions, yet the subject of Kashmir can push them to the brink of annihilation. Fifty years of animosity have built up as a result. A proxy war still brews in Kashmir, claiming dozens of lives every†¦show more content†¦They removed the ruler of Junagarh and placed a â€Å"Provisional Government† in place, then used the excuse of â€Å"restoring law and order† to invade and hold a farcical plebiscite, which choose Ind ia. â€Å"India sought to justify its aggression†¦on the plea that the rulers of Junagarh and Hyderabad were acting against the wishes of their people† states the report on Kashmir released by the Pakistani Foreign Ministry. Keep this excuse in mind as you read on; the rulers of the states were acting against the will of the people, so India felt it had the moral right to interfere. In Kashmir, the roles were reversed. The ruler was Hindu with a Muslim majority. Anticipating that the ruler would chose India, the people rose against him, and with the support of Pakistani tribesmen, ousted the ruler and set up their own government. Now the irony of the situation is that while the Indians did the exact same thing in Junagarh, they could not accept the state of affairs in Kashmir. The provisional government of Kashmir chose Pakistan, and a few days later the ousted ruler of Kashmir signed over the state to India, despite no longer being technically in power. The Indian army then invaded, with the Pakistani army following suit, and war broke out between the fledgling nations. The United Nations intervened in 1948 and set up a shaky ceasefire temporarily splitting Kashmir into Indian-held and Pakistani held areas. As the countries were divided in AugustShow MoreRelatedKashmir Issue1534 Words   |  7 Pagesreturn home by the dusk. That’s the fear that the peop le of Kashmir are living with. Freedom, for Kashmir, is a search for the lost identity of its rich cultural religious class of medieval world. The issue of Kashmir is not as ordinary as most of the people in India think. People of Kashmir are dying dying for the future of their unborn. I just want to convey to the outer world the citizens of India that the common man in Kashmir is not a terrorist but a human being who has needs like anyoneRead MoreEthnic Tourism Essence of India7906 Words   |  32 Pageslet’s feel the experience and see how Ethnic tourism has helped promoting tourism and bringing world closer. Introduction India known as Visitor’s paradise derives her roots from a rich past both culturally and historically. This is manifest in the wealth of its cities and magnificent architecture. Starting from the tip of snowcapped mountains of Kashmir to beautiful landscapes allover to Kanyakumari there are enormous stories of cultural and ethnic wonders. There are scores of existing locations forRead MoreA Study on Role of Advertisement in Promotion of Tourism in India15524 Words   |  63 Pagesand Buddhist temples. Many  trekkingexpeditions also begin here. JAMMU AND KASHMIR Jammu amp; Kashmir  is known for its scenic landscape .Jammu and Kashmir  is the northernmost state of India.  It is also called as Paradise on Earth. ATTRACTIONS * Jammu  is noted for its scenic landscape, ancient temples and mosques, Hindu and Muslim shrines, castles, gardens and forts. * The Hindu holy shrines of Amarnath in  Kashmir Valley  attracts about   Vaishno Devi  also attract thousands of Hindu devoteesRead MoreHimachal Pradesh8795 Words   |  36 PagesHimachal Pradesh Himachal Pradesh is a state in Northern India. It is spread over 21,495 sq  mi (55,673  km ²)and is bordered by the Indian states of Jammu and Kashmir on the north, Punjab on the west and south-west, Haryana and Uttar Pradesh on the south, Uttarakhand on the south-east and by the Tibet Autonomous Region on the east. The literal meaning of Himachal Pradesh is Region of snowy mountains. Himachal Pradesh was anciently known as Dev Bhumi (The Abode of Gods) and is known to be abundant inRead MoreRise and Decline of the Muslim Ummah9373 Words   |  38 PagesEastern Europe until it reached the borders of Vienna. On the other side, it took upon itself, the responsibility of leadership and security of the entire Islamic world, including Northern Africa. It also revived the Caliphate, and in this way the lost splendour and grandeur of the Islamic world was once again restored. The important point to note here is that this task was performed by the Turks and not by the Arabs. Strange are the ways of Providence! The consolidation the Usmanian Caliphate producedRead MoreIndian English Novel17483 Words   |  70 Pagesanthologies, and in some instances bound compendiums of previously published comic book series). These novels are imbibed with life through both speech and images. Some of the popular graphic novels created in India comprise - The Believers, Corridor, Kashmir Pending and The Barn Owl`s Wondrous Capers by various novelists, likening themselves to the range of comic book popularisation. The contemporaneous Indian novels are widely sold and flying off the racks in overseas countries, besides just the native

Essay on Homer’s Odyssey Free Essays

In the tenth book of the Odyssey Odysseus and his companions find themselves trapped in the cave if the Cyclops Polyphemos. After their monstrous host has munched his way through several of his guests, the remainder take action. Odysseus makes a sharp, wooden stake, cutting it from the massive cudgel discovered in the cave; then together with four of his men he plunges the stake into the eye of the drunken, sleeping Polyphemos. We will write a custom essay sample on Essay on Homer’s Odyssey or any similar topic only for you Order Now Snodgrass, however, would dissent. His whole book is devoted to proving that not only did early Greek art rarely illustrate Homer, it was rarely even inspired by it. This theory is not a new one. Many other scholar have thought and pondered the same ideas. Snodgrass meticulously studies examples of scene often thought to be illustrations of Homer. Geometric art, he argues, offers nothing that can be identified as Homeric; indeed, there is only one Trojan war scene and that is Ajax’s rescue of the body of Achilles, a scene which occurs in neither the Odyssey nor the Iliad. One of the more bizarre apparitions of geometric art takes the form of a pair of Siamese twins, warriors with two heads, four legs, four arms and one torso and the subject of some fascinating pages in Snodgrass’s book. They were especially popular in early Greek art, but there is no clear Homeric influence here. Twice does the Iliad does refer to the twins, yet significantly he does not mention their rather striking deformity. It is preferable to understand both the artist and Homer as drawing on the same body of legendary material. By the mid seventh century figures on vases are beginning to be identified by captions. This at least makes it easier to determine whether the scene is from the Trojan war. Instead of two warriors fighting over a body we can be sure that we are looking at Menealos and Hektor fighting over the body of Euphorbos, as found on a famous Rhodian plate of the late seventh century, a picture that makes an impressive and appropriate cover for the book. This could very well be an illustration of the Iliad book where Menealos abandons his attempt to strip the corpse. Evidence for this tradition can be found in the shield of Euphorbos by Menealos himself. This is certainly plausible and helps to show that common subject matter is insufficient to prove influence. On the other hand, where a minor character is names, such as ‘Odios’ in the embassy to Achilles, then we can be more confident that the artist had Homer in mind. This is a book of enormous leaning and subtlety, and it conclusion is surely right, yet at the same time it seems something of a missed opportunity. It is devoted to a negative and tightly-argued thesis, that Homer’s epic poems had only minimal influence on early Greek at. Snodgrass is re-thinking early Greek art as he goes, but he is re-thinking it within the restrictions imposed by the very narrow focus of the book as a whole. Thus, the positive, for instance the illuminating chapter on synoptic narrative and on composition, can be rather swapped in the relentless negative arguments. Other will now need to work through the implications of his thesis, for example the role that must be assigned to oral tradition and all its local variations. Perhaps it is no conscience that his book should appear at a time when the literary culture of the recent past is being eroded by an increasing emphasis on the visual. How to cite Essay on Homer’s Odyssey, Essays

Yellow Raft In Blue Water Essay Research free essay sample

Yellow Raft In Blue Water Essay, Research Paper ? When authors write from a topographic point of penetration and existent lovingness about the truth, they have the ability to throw the visible radiations on for the reader. ? ( Anne Lamott ) When a reader can see a state of affairs in a distinguishable and realistic manner that entreaties to his emotion, he knows that the author has written with great penetration. With experience, authors can show the deeper significance of a clip or state of affairs. In A Yellow Raft in Blue Water, Michael Dorris exhibits this technique when he writes about Christine go forthing Rayona at Ida? s house. We will write a custom essay sample on Yellow Raft In Blue Water Essay Research or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The 1920? s is viewed as a comfortable and glamourous clip period, but F. Scott Fitzgerald tells us otherwise. In The Great Gatsby, Fitzgerald unveils the world of peoples? lives in the 1920? s by stating the narrative of Jay Gatsby. In A Yellow Raft in Blue Water, Christine is sick, and she leaves Rayona at Ida? s house. Dorris is able to? throw the visible radiations on for the reader? , because the reader views this state of affairs through two positions. Rayona thought that Christine was being selfish for go forthing her with Ida. She felt that her female parent was non looking out for her, and pretermiting her. However, when one views the fortunes through Christine? s eyes, the reader discovers that Christine left because she did non desire Rayona to see what she was traveling through. Christine besides did non desire Rayona to experience bad for her. Michael Dorris tells the narrative through two diffe rent positions, so the reader can feel the world and truth of what each character is experiencing indoors. In The Great Gatsby, F. Scott Fitzgerald does non portray the 1920? s as a clip of wealth, felicity, and excess like it is believed to be. Fitzgerald uses the character, Jay Gatsby, to demo the reader that this clip period was non all about felicity and joy. Gatsby is a adult male who did non cognize what existent love was. He had the fancy autos, and the beautiful house, but he did non hold Daisy. Fitzgerald is seeking to demo the reader that non everyone who had money in this clip period was happy. Fitzgerald writes the manner it truly was, leting the reader to understand what people were similar at this clip. Another realistic character in The Great Gatsby is Daisy Buchanan. Daisy? s hubby, Tom, was a really successful person, who had money, luxuries, and a large house. Daisy was still non happy and had an matter with Gatsby. The world was that everyone was non happy with their lives. Many people had jobs and Fitzgerald shows this in his work. Finally, when authors write with penetration, the reader is able to understand the truth about the state of affairs. Many plants of literature do non state the truth, and the reader is non able to experience what is traveling on in the book. Michael Dorris and F. Scott Fitzgerald do a phenomenal occupation in conveying the reader down to Earth. The authors use their cognition of the clip period to compose practically.