The Resource Transfer-price rules on the sale of tangible goods between related multinational corporations

Transfer-price rules on the sale of tangible goods between related multinational corporations

Label
Transfer-price rules on the sale of tangible goods between related multinational corporations
Title
Transfer-price rules on the sale of tangible goods between related multinational corporations
Creator
Subject
Summary
Facts: Selco, a corporation in host country H, is in the business of manufacturing and selling specialty chemicals throughout the world. Selco owns 100 percent of the stock of Subco, a corporation in foreign country F for the purpose of marketing Selco products outside country H. The rate of tax on the sale of goods sold by a country H corporation is higher than worldwide tax rates generally. Selco sells its products to Subco at a price equal to cost plus 6 percent; Subco thereafter resells Subco chemicals in the worldwide market at its invoice cost plus 50 percent. Question: To what extent will country H require a redetermination and reallocation of the profits realized on the sale of Selco chemicals to Subco?
Citation source
In: Tax Management international forum. - London. - Vol. 1 (1980), no. 2 ; p. 1-31
http://library.link/vocab/creatorName
Malherbe, J.
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • allocation of profits
Label
Transfer-price rules on the sale of tangible goods between related multinational corporations
Instantiates
Publication
Contents
Belgium p. 3; Canada p. 4-5; Denmark p. 6-7; France p. 8-10; Germany p. 11-13; Ireland p. 14-16; Italy p. 17-18; Japan p. 19-20; Netherlands p. 21-23; UK p. 24-26; USA p. 27-31
Label
Transfer-price rules on the sale of tangible goods between related multinational corporations
Publication
Contents
Belgium p. 3; Canada p. 4-5; Denmark p. 6-7; France p. 8-10; Germany p. 11-13; Ireland p. 14-16; Italy p. 17-18; Japan p. 19-20; Netherlands p. 21-23; UK p. 24-26; USA p. 27-31

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