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Journal articles on the topic 'Advance pricing arrangements'
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1
Valente, Piergiorgio. "Advance Pricing Arrangements: Optimal Tool – Optimal Framework?" Intertax 48, Issue 1 (January 1, 2020): 67–73. http://dx.doi.org/10.54648/taxi2020005.
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Advance Pricing Agreements (APAs) are a diffused tool for taxpayers to obtain certainty in relation to the tax impact of their cross-border activities through an agreement with a tax administration in advance of such activities. APAs can be unilateral, bilateral, or multilateral depending on the number of national tax administrations involved, the latter two promising that the agreement made shall not be questioned in the other affected tax jurisdiction. Departing from the enhanced mutual agreement procedure (MAP) framework recently established among Member States through the Tax Dispute Resolution Directive, a future EU legislative initiative could outline a robust framework for MAP APAs in the Single Market. Advance Pricing Arrangements, Dispute resolution, MAP – Mutual agreement procedures, Administrative Cooperation, BEPS, Transparency, Fiscal Stateaid, Transfer Pricing
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Kuropka, Karolina. "Advance Pricing Arrangements as a Tax Strategy Tool for Related Entities." European Financial and Accounting Journal 15, no. 2 (December 15, 2020): 31–44. http://dx.doi.org/10.18267/j.efaj.240.
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Brodzka, Alicja. "Better governance through more transparency on advance cross-border tax rulings." Journal of Governance and Regulation 6, no. 1 (2017): 7–11. http://dx.doi.org/10.22495/jgr_v6_i1_p1.
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In recent years, the challenge posed by tax fraud and tax evasion has increased considerably and has become a major concern within the European Union. As a consequence, in the European initiatives a special emphasis has been laid on the actions aimed at reinforcing the anti-abuse provisions in bilateral tax treaties, national legislation and EU corporate legislation. Any artificial arrangement carried out for tax avoidance purposes would be ignored and companies would be taxed instead on the basis of actual economic substance. The aim of the article is presenting the European initiative aimed at implementing the automatic mode of the exchange of information on cross-border tax rulings and advance pricing arrangements. The paper investigates if the implemented measure can help Member States to detect certain abusive tax practices taken by companies, and to take the effective actions in response. It also tries to answer the question whether the initiative can result in more transparency and – as a consequence – in much better governance, both at the states’ and the corporations’ level.
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Borkowski, Susan C. "The history of PATA and its effect on advance pricing arrangements and mutual agreement procedures." Journal of International Accounting, Auditing and Taxation 17, no. 1 (January 2008): 31–50. http://dx.doi.org/10.1016/j.intaccaudtax.2008.01.004.
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KOSCHUK, Tetiana. "Agreements between tax authorities and taxpayers in the context of EU law on state aid." Fìnansi Ukraïni 2021, no. 1 (March 18, 2021): 64–82. http://dx.doi.org/10.33763/finukr2021.01.064.
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This article analyses how the application of the EU legislation on state aid has impacted the development of cooperation between tax authorities and taxpayers through the various forms of agreements they enter into. These measures of tax administration may qualify as state aid to business entities only if they meet all the criteria for such aid, namely: they should offer an economic advantage to the beneficiary; they should be granted by the state or through state resources; they should be selective; they should distort competition and have an adverse impact on trade. Furthermore, there are some areas to which the general rules of state aid do not apply. The latter include, among others, the operations of agricultural industries and the actions the state is obliged to take under international treaties. The analysis of the European Commission's approaches and case law has given rise to the following conclusions: 1) the write-off, instalment and deferral arrangements for the tax debt of insolvent economic entities will qualify for state aid only if it is proven that more funds would have made it into the budget had the corresponding agreements not been in place (in particular, if the taxpayer had gone bankrupt); 2) to recognize the consequences of the violation of transfer pricing rules as state aid when entering into advance pricing agreements, it is crucial to unequivocally prove that tax legislation has been violated and prove that, in view of all other opportunities for taxation under the "standard" conditions, the company has in fact paid less taxes; 3) involvement in joint legal compliance programs will not be considered a provision of state aid if the terms of such cooperation provide only procedural benefits to the parties to the agreements, rather than entailing any reduced tax liability for a business entity.
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Aidelojie, Kenneth. "Multilateral Organisations,Fossil Fuels and Energy Law and Policy: The Tower of Babel Re–visited." European Energy and Environmental Law Review 17, Issue 4 (August 1, 2008): 227–55. http://dx.doi.org/10.54648/eelr2008021.
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In recent weeks, it appears that regulatory and related policy interest in OPEC and other oil producers rises in direct proportion to the price of oil. On 26–27 June, European Union representatives will be travelling to Siberia in order to seek new regulatory arrangements on oil and gas imports, as well as concessions in relation to Western European investment in the Russian energy sector. Prime Minister Gordon Brown is in Saudi Arabia, seeking regulatory concessions related to higher production levels for oil in order to force prices down. Against this backdrop, he has threatened to spend up to £100 billion (C=127 billion) weaning citizens off the expensive energy imports that threaten family budgets. Similarly, in the recent presidential primaries in the United States, Hillary Clinton promised to bring legal action against OPEC in relation to its cartel status. Notwithstanding the implicit evidence of the weak bargaining power of consumer nations that are forced to visit producer nations for “constructive talks, there is much to commend scholarly attention to the role of regional and multilateral institutions in relation to fossil fuels regulation at this time. This article analyses the role of these institutions (Section 1) particularly in relation to OPEC, against the backdrop of the energy dependency (Section 2) that has evolved among leading oil consumer nations. In Section 3, we scrutinize dual energy pricing, as well as the trade compatibility of one of the EU’s answers to oil dependency, the Renewable Energy Sources Directive. We then proceed to analyse unilateral and multilateral litigation prospects in respect of OPEC’s export regulatory control practices (Section 4) prior to offering some constructive concluding remarks. In view of the current third wave international energy crisis, it is right that multilateralism should serve as a sensible way forward given the abject failure of individual consumer states thus far to both advance a sustainable energy security regulatory and policy framework and, in an integrated fashion, to address the challenges of climate change.
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Markham, Michelle. "Advance Pricing Arrangement Reform in Australia: Was It Worth the Wait?" Intertax 40, Issue 1 (January 1, 2012): 63–74. http://dx.doi.org/10.54648/taxi2012006.
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In June 2007, the Australian Taxation Office (ATO) announced that it had tendered for an independent review to evaluate the role and performance of its Advance Pricing Arrangement (APA) Program. Following the submission of the Review Report in 2008, the ATO took steps to co-design, together with industry representatives, a more efficient and effective system that would satisfy the needs of both internal and external stakeholders and be sustainable in the long term. The revitalized APA Program was finally introduced in March 2011. This article will discuss and analyse the efficacy of the changes brought about by the new Program.
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Koo, Hui-Wen, and Chun-Chieh Wang. "Indexed Pricing: Sugarcane Price Guarantees in Colonial Taiwan, 1930–1940." Journal of Economic History 59, no. 4 (December 1999): 912–26. http://dx.doi.org/10.1017/s0022050700024074.
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In Taiwan during the Japanese colonial period, sugarcane was typically purchased by Japanese-owned sugar mills at prices guaranteed long in advance of delivery. In some places, the future price was indexed to the price of rice in the following year. This study points out that indexing served to insure farmers' real incomes. But as an insurance against an aggregate risk, this arrangement threatened the mill's profits. We investigate why mills nevertheless offered the insurance.
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Rhyn, Jacques van, and Janelle Sadri. "LNG pricing trends and key considerations." APPEA Journal 55, no. 2 (2015): 417. http://dx.doi.org/10.1071/aj14052.
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Historically, LNG has been sold through long-term contracts with limited flexibility in volume and price. LNG trade patterns have evolved significantly, adding to increased sales of multiple cargoes on the spot market, brokered trades and speculative trading positions being taken up by non-traditional players. Buyers in the Asia-Pacific region are keen to secure supply for local markets, while Australian producers, particularly subsidiaries of foreign headquartered groups, are under pressure to sell at competitive prices. From a transfer pricing perspective, the Australian Taxation Office (ATO) has placed increased scrutiny on the commerciality of arrangements, arm’s length outcomes and profit allocations between Australian taxpayers and their international related parties (e.g. marketing and trading hubs). This extended abstract covers: factors that could impact on the selection of a price index and the slope or gradient to be applied in pricing formulae; blended pricing based on an average of different indices, and why pooling and trading may make commercial sense, although revenue authorities may not look favourably upon it; the importance of the contractual terms, the market situation and the other commercial contract conditions on the pricing of related-party LNG sales; and, the value in potentially seeking an advanced pricing agreement in a related party LNG pricing context, given the significance of the transactions. Given the practical and commercial challenges facing the industry and with several projects commencing production in the relatively near future, this is very topical. The authors use case studies to illustrate the key concepts.
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Adesi, Michael, De-Graft Owusu-Manu, and Roisin Murphy. "Strategic competences for pricing quantity surveying consultancy services." Engineering, Construction and Architectural Management 25, no. 3 (April 16, 2018): 458–74. http://dx.doi.org/10.1108/ecam-12-2016-0264.
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Purpose Professional quantity surveying (QS) services are critical to successful delivery of construction projects within planned budget, quality and duration. The supply of QS professional services is largely dependent on the price level of services and the willingness of clients to pay. The pricing of professional QS consultancy services has been confronted with a myriad of pricing challenges due to rapid changes in the business environment; the pervasive influence of information technology; and the complexity of clients’ expectation. It is therefore necessary for QS consultancy firms to develop strategic competences for the pricing of their services. In addition, numerous studies have not given the pricing the pricing of professional services the requisite attention. The purpose of this paper is to investigate the strategic competences for pricing professional QS services. Design/methodology/approach The study was positioned within the positivist tradition. As a result, the quantitative approach was adopted using a survey questionnaire to collect data from QS consultants. The sample size of the study was 79 professional quantity surveyors chosen by using simple random sampling technique from a population of 372 registered professional QS of the Ghana Institution of Surveyors. Using the χ2 test and factor analysis, the study established relationship between strategic competences and pricing of QS services. Findings The study found that strategic competences for pricing QS professional services is significantly related to the managerial and professional competence of QS consultants. The strategic competences of QS consultants identified by this study include business management, services cost management; and production capabilities. Practical implications This study provides an empirical basis for QS consultancy firms to focus on strategic direction of their contractual arrangement with clients. Practically, resource configuration and on strategic competences for professional service pricing would create price leadership. Originality/value The study advances the pricing knowledge within the QS practice by demonstrating the nexus between strategic competences and the pricing of QS professional services which hitherto this study have not been effectively investigated.
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Schramm, Engelbert, Dennis Becker, and Michaela Fischer. "Advanced processed wastewater for different uses: constellations favouring future implementation of a multimodal water reuse concept." Journal of Water Reuse and Desalination 10, no. 4 (November 25, 2020): 284–300. http://dx.doi.org/10.2166/wrd.2020.043.
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Abstract Advanced wastewater treatment is often used to produce one single water quality. In recent years, technologies have been developed that allow the production of different qualities that are fit for their purpose. These technology bundles are still not being marketed, and market requirements are unclear. Two constellations in West Basin, California and in Oman were analysed to shed light on the different constellations of actors, resource situations and institutions. The first led to the industrial reuse of several water qualities, while the second produced an application in holiday resorts, leisure and food production. A hypothetical solution was contrasted with an historical case. The analysis of the constellations showed that multi-sectoral investments and dependencies require strong cooperation arrangements and long-term agreements. Governmental institutions were revealed to be suitable for coordinating the process, especially during the initial phase, but also in view of security of supply. A (comparative) examination allows an initial, still provisional systematic overview of other constellations that favour systems with recycled water of different qualities. Further research is required to understand the welfare and distribution effects of multimodal water pricing policies and the feasibility of co-financing of agricultural irrigation and opportunities for more sustainable water reuse.
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Chan, Daniel. "China Tax Scene: The Implementation Rules of the SAT on Advanced Pricing Arrangements ('APAs') for Related-Party Transactions (Guo Shui Fa [2004] No. 118)." Intertax 33, Issue 1 (January 1, 2005): 46–48. http://dx.doi.org/10.54648/taxi2005007.
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Beck, Thomas J. "Revolution and Protest Online." Charleston Advisor 23, no. 2 (October 1, 2021): 43–46. http://dx.doi.org/10.5260/chara.23.2.43.
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Revolution and Protest Online is an Alexander Street resource, which provides documents, images and videos on revolutions and resistance, protest, and social movements from the eighteenth to the twenty-first centuries. It can be purchased as a standalone collection with a perpetual access license, or it can be accessed as a Related Collection through a subscription to Global Issues Library, another Alexander Street resource. This database contains original documents and images in PDF format, as well as e-books, monographs, journals, and videos. These are drawn from a variety of national and international sources, and collectively represent several hundred images, almost 200 videos, and nearly 100,000 pages of content.This database is not difficult to navigate, and finding materials there is relatively easy, using either the basic or advanced searches or through browsing. These various search and browse functions can produce useful results, and are easily understandable, though the advanced search is arguably the most flexible and effective (but also the most complex!). Pricing for this database is based on an institution's budget, FTE, and whatever consortia arrangements it and other institutions make with the vendor. As a consequence, its price can vary considerably from one subscriber to another! For a specific price quote, contact Alexander Street. Its licensing agreement is quite average in its length and composition and is apparently the standard one for the vendor. The quality, quantity, and variety of materials in this database is notable. It will certainly be of use to those researching the political, historical, and social aspects of revolution and protest, both in the United States and around the world. However, given its price variability, it may only be of marginal value to institutions with a high purchase/subscription price and a low demand for these kinds of materials.
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Huibers, Fred E. "Towards an Optimal IPO Mechanism." Journal of Risk and Financial Management 13, no. 6 (June 4, 2020): 115. http://dx.doi.org/10.3390/jrfm13060115.
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Concerns about the negative consequences of the excessive underpricing of the current arrangement in the initial public offering (IPO) market for the provision of entrepreneurial finance—book building—have led to research into the viability of auctions for IPO pricing and allocation. IPO firms face a trade-off between the benefit of accurate and reliable IPO price discovery and the cost of underpricing. The main aim of this paper was to gain new scientific knowledge about this trade-off by measuring the impact of two key variables on this trade-off: capacity restraint and discount on the auction clearing price. Using controlled experiment methodology in multi-unit uniform price auctions we found that the most capacity-restricted auctions that also offer investors a discount are likely to produce the most accurate and reliable price discovery and consequently, the most predictable auction outcome. There are indications that a discount of 8% may suffice to incentivize investors to reliably contribute to price discovery. The resulting underpricing (and its variability) of these auctions is likely to be significantly lower than if book building would be used to price and allocate IPOs. Technological innovation in the IPO market through the application of recent advances in data science, experimental economics and artificial intelligence allows for the optimization of IPO mechanisms and crowdfunding platforms which in turn improves the access to equity required for entrepreneurial finance.
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Gujjarwar, Shriniwas, and Poonam Arya. "Concept of Vidradhi WSR to abscess: an ayurvedic review." International Surgery Journal 8, no. 12 (November 26, 2021): 3767. http://dx.doi.org/10.18203/2349-2902.isj20214783.
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Ayurveda, a characteristic arrangement of medication, started in India over 3,000 years prior. The term Ayurveda is taken from the Sanskrit words ayur (life) and veda (science or information). In this manner, Ayurveda means information on life. In the wake of Collecting the information from various samhitas, ayurvedic texts and current books. Acharya sushruta- the father of Indian surgery has logically characterized in a foundational way an abundance of clinical material and the standards of the board for vidradhi, which are legitimate even today. "Sheegra vidhahivat'' meaning of vidradhi itself recommends the destructiveness of the disease. Vidradhi word is advanced from vidra, i.e, a painfull condition like pricking, stabbing or cutting sensation in the skin. The infection Vidradhi (abscess) is a typical infirmity disturbing mankind and debilitate the victim for his standard work. It presents as a limited expanding with torment, red discoloration,local rise of temperature, delicacy and confined capacity of impacted part. it is normal in India with second most noteworthy frequency because of helpless disinfection, stuffing and deficient sustenance. Around the world, roughly 40-50 million individuals are contaminated every year with amoebic abscesses. The current exploration article is intended for relative investigation of Vidradhi and Abscess as far as Samprapti (Pathophysiology), Lakshanas (Clinical elements) and Chikitsa (Treatment) affirms that Vidradhi and Abscess can be comparable disease entities.
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Houyez, François, and Rob Camp. "OP27 Engaging Patients: The EuroCAB Programme." International Journal of Technology Assessment in Health Care 35, S1 (2019): 6. http://dx.doi.org/10.1017/s0266462319000989.
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IntroductionWhen developing a health technology that requires clinical studies, developers institute working relations with clinical investigators. In certain diseases areas, patients' representatives create their own advisory boards, which proved their utility in the early 90s, in particular for the development of products to treat HIV infection. Inspired by this model, where patients with a same disease join and meet with relevant developers and discuss all aspects of the research, the European Organisation for Rare Diseases (EURORDIS) proposes a new programme of such Community Advisory Boards for Rare Diseases (CAB).MethodsFor this programme, EURORDIS invites developers to sign a Charter of principles when engaging with patients, and provides guidelines on CABs, together with a mentoring programme for patients’ networks that are less experienced with the development and the evaluation of health technologies. CABs are driven by patients who set their agenda, who sign a Memorandum of Understanding with each developer, and who organise the sessions. Sessions typically last for two to four days during which different meetings with different developers can take place, or trainings. All meetings can take place under confidentiality arrangements, and minutes are written to keep track and to follow-up with all points discussed. Participants and agendas are made publicResultsAs of 2018, four CABs exist and operate (for tuberous sclerosis complex, for scleroderma, for cystic fibrosis, for Duchenne muscular dystrophy) and 18 others are in discussion with many due to start in 2019. Topics discussed cover the target population, the study feasibility, the endpoints including patient reported outcomes, the comparator choice and/or the acceptance of a placebo controlled trial, the quality of life, the practical aspects of the trials, and the identification of previously unknown or unmet patient needs/preferences. For products which are more advanced in their life-cycle, discussions can also cover compassionate use, pricing policy, relative efficacy etc.ConclusionsThis represents a well-structured programme for the engagement of patients, where collective thinking and exchange between different patients ensure high quality dialogue with developers and can inform HTA also.
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"Polish advance pricing arrangements in the context of the directive on mandatory automatic exchange of information in the field of taxation." Studia Prawno-Ekonomiczne 109 (2018). http://dx.doi.org/10.26485/spe/2018/109/11.
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Buttignon, Fabio. "Distressed Firm Valuation: A Scenario Discounted Cash Flow Approach." Journal of Business Valuation and Economic Loss Analysis 15, no. 1 (September 10, 2020). http://dx.doi.org/10.1515/jbvela-2020-0002.
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AbstractValuation of a distressed company is a very tricky issue, for which many approaches and methods have been provided by the literature. Unfortunately, many of the more suitable proposals from a theoretical point of view (i.e., those based on option pricing theory, and even integrated with game theory) are very difficult to apply to real cases. To face the many contingencies emerging in a real case valuation, a scenario discounted cash flow (SDCF) model is provided here. The focus is on companies at an advanced stage of distress, where their ability to operate as a going concern is in question, and maintenance or recovery of business continuity requires significant interventions in the firm’s strategic, operational, and financial structure. In this context, SDCF, with a number of arrangements elaborated here, appears useful for valuing assets, debt, and equity – from current or potential new investors – and the interactions between them, which are particularly critical for distressed companies. At the same time, SDCF takes into account the firm’s liquidation option, not only at the valuation date but even after a restructuring plan has been launched. The going-concern value including the liquidation option should be the reference point for judging the suitability of business continuity compared to liquidation. In presenting the model, the key concepts and methodology adopted are set out following a numerical example inspired by a real case.