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Author(s): 

XU B.

Issue Info: 
  • Year: 

    2000
  • Volume: 

    62
  • Issue: 

    2
  • Pages: 

    477-493
Measures: 
  • Citations: 

    2
  • Views: 

    193
  • Downloads: 

    0
Keywords: 
Abstract: 

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

View 193

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Issue Info: 
  • Year: 

    2012
  • Volume: 

    4
  • Issue: 

    1
  • Pages: 

    5-26
Measures: 
  • Citations: 

    0
  • Views: 

    315
  • Downloads: 

    104
Abstract: 

Using firm-level panel data for Korean MNEs, we make a distinction between being the only affiliate of a parent firm and being the one of the multiple affiliates of a parent firm. Comparisons of correlations between purchases and sales of each group of the foreign affiliates show distinctive difference in the motivations of FDI and the multinational activities, due to the difference in the number of affiliates they possess. Our main empirical results in this paper suggest that productive Korean MNEs not only enlarge their host countries of FDI but also enlarge the number of affiliates in a same host country. We interpret these FDIs are motivated by enjoying information and network advantages by gathering in one location.

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

View 315

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Author(s): 

BUCKLEY P.J. | HORN S.A.

Issue Info: 
  • Year: 

    2009
  • Volume: 

    42
  • Issue: 

    4
  • Pages: 

    495-517
Measures: 
  • Citations: 

    1
  • Views: 

    111
  • Downloads: 

    0
Keywords: 
Abstract: 

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

View 111

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Author(s): 

HABIBI ALIREZA |

Issue Info: 
  • Year: 

    2012
  • Volume: 

    3
  • Issue: 

    1
  • Pages: 

    99-112
Measures: 
  • Citations: 

    0
  • Views: 

    4416
  • Downloads: 

    2118
Abstract: 

This study aims to evaluate the marketing strategies of ten selected multinational corporations in Philippine. During the study evaluating three questions were presented to be answered, the question about affection of government policy to marketing strategies in the selected corporations, the strategies which were practiced by these corporations and at the end the question about the marketing problems which corporations were encountered to. At the end we concluded that the Philippine government policies on investment and trademarks are an attractive to corporations. And distribution channels and motivation of cooperation for every enterprising differs in various situations and corporation encountered to the motivation practices or they have to completion with other foreign corporations. For obtaining to these findings the study utilized the descriptive method Tutor which was deemed most appropriated to this study, and also in data-gathering additional to questionnaire, we used from documentary evidences, and interviews too.

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

View 4416

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Author(s): 

MARKUSEN J.R.

Issue Info: 
  • Year: 

    1997
  • Volume: 

    9
  • Issue: 

    2
  • Pages: 

    169-189
Measures: 
  • Citations: 

    1
  • Views: 

    138
  • Downloads: 

    0
Keywords: 
Abstract: 

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

View 138

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Author(s): 

LEHMANN H. | GALLUPE B.

Issue Info: 
  • Year: 

    2005
  • Volume: 

    11
  • Issue: 

    2
  • Pages: 

    163-186
Measures: 
  • Citations: 

    1
  • Views: 

    92
  • Downloads: 

    0
Keywords: 
Abstract: 

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

View 92

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Author(s): 

ANDERSEN T.J. | FOSS N.J.

Issue Info: 
  • Year: 

    2005
  • Volume: 

    11
  • Issue: 

    2
  • Pages: 

    293-310
Measures: 
  • Citations: 

    1
  • Views: 

    108
  • Downloads: 

    0
Keywords: 
Abstract: 

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

View 108

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Journal: 

PRIVATE LAW

Issue Info: 
  • Year: 

    2024
  • Volume: 

    12
  • Issue: 

    45
  • Pages: 

    241-282
Measures: 
  • Citations: 

    0
  • Views: 

    16
  • Downloads: 

    0
Abstract: 

Tax has undeniable role in Provision of the governments general budget and special position in financial regime of all oil and gas contracts. Host states always trying to provide presence and investment conditions of multinational enterprices in oil and gas industry for advancing their economic goals and collecting considerable Income tax. Although multinational enterprises are important actors in the international trade and one of the main factors of global economic growth, the destructive effects of some of their actions are not desireable. The structure of these companies is somehow that parent company controls and manages many subsidiary companies in various countries and advances its besiness goals in any way possible. This structure provides for these companies the possibility of tax avoidance via transfer pricing mechanism. In international oil and gas industry, a significant volume of transactions are between parent company and its subsidiary companies or between subsidiary companies of a parent company. Transfer pricing is a mechanism based on that goods. services, rights and property related to intellectual property, facilities and ... transfer from parent company to subsidiary or between subsidiaries of parent company at a price different from the usual market price. Indeed, the purpose of utilization of this mechanism is internalization of transactions and determining desired prices for the purpose of reducing taxable income and transfer of funds from geographic territory with a high income tax rate to another geographic territory with a low income tax rate. Host countries tax revenues affected by this action of multinational companies. Host countries with the aim of collecting maximum tax revenues determine financial regime of oil and gas contracts, whiles controlled transactions of multinational enterprises obstruct this goal. Transfer pricing violates competition law to the detriment of small companies. Although multinational enterprises with their structure internalize transactions, avoid tax payment and save financial resources resulting from it easily, but small companies do not have such a capability, can not avoide tax liabilities and invest financial resources resulting from it in other sectors. Oil and gas industry due to the need to huge investment and modern technologies is desprately depending on the presence of multinational companies, and a very high turnover of money increase  the motivation of those companies in the utilization of transfer pricing mechanism. Supply of required goods and services from affiliated companies at a price outside the normal market price and providing facilities with an interest rate higher or lower than the usual rate reduce tax income of host states and create many challenges to deal with this problem. Utilization of Arm's-Length principle is the most efficient tool to deal with transfer pricing. Based on this principle, if the price of goods and services exchanged in controlled transaction between two related companies differ from the usual price of those goods and services in uncontrolled transaction between two independent companies, tax experts ignore the price of controlled transaction and base the price of uncontrolled transaction for calculation of taxable income. This principle is universal and the method of its applying has been predicted in the tax laws and regulations of most countries. It is determined, By examining judicial precedent of countries, that tax experts, in calculating the due tax, ignore price announced by tax payer and by applying this principle determine taxable income. Despite all the advantages of the arm's-length principle, the challenges of its application cannot be overlooked. Comparative analysis is the basis of applying this principle and to do this, tax experts should find similar transaction related to same goods or services exchanged in a controlled transaction to compair price. In most cases, desired goods and services are unique and finding a similar transaction is impossible. This research, with the library method and examining judicial precedent, explains the transfer pricing of multinational companies with the special attention to the international oil and gas industries to find out that how these companies, by internalization of transactions and determination of their desired price, avoid paying tax to host governments. In the following, coping with transfer pricing by applying arm's-length principle, methods of applying this principle and Iran's legal status in dealing with this problem will be reviewed to find out that which legal instruments Iranian National Tax Administration has to deal with transfer pricing.

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

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Author(s): 

CANTWELL J.

Issue Info: 
  • Year: 

    2009
  • Volume: 

    40
  • Issue: 

    1
  • Pages: 

    35-41
Measures: 
  • Citations: 

    1
  • Views: 

    162
  • Downloads: 

    0
Keywords: 
Abstract: 

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

View 162

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Author(s): 

JOHNY K.J. | ISRAEL D.N.

Issue Info: 
  • Year: 

    1986
  • Volume: 

    17
  • Issue: 

    3
  • Pages: 

    101-126
Measures: 
  • Citations: 

    1
  • Views: 

    103
  • Downloads: 

    0
Keywords: 
Abstract: 

Yearly Impact: مرکز اطلاعات علمی Scientific Information Database (SID) - Trusted Source for Research and Academic Resources

View 103

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