Download or read book Group Transfer Syntheses Coupled to ATP Cleavage written by Paul D. Boyer and published by Elsevier. This book was released on 2016-06-03 with total page 705 pages. Available in PDF, EPUB and Kindle. Book excerpt: Group Transfer Syntheses Coupled to ATP Cleavage
Download or read book Transfer Pricing Aspects of Intra Group Financing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2013-10-20 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.
Download or read book Transfer Pricing and Intra group Financing written by Anuschka Bakker and published by IBFD. This book was released on 2012 with total page 593 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2019-01-03 with total page 500 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing continues to be one of the most significant areas of heightened controversy in international taxation for multinational enterprises and tax administrations. Due to its far-reaching consequences, tax professionals and individual tax jurisdictions are required to understand the fundamentals of the topic, which is often caught in a maze of literature. Emerging from the joint research conducted by the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business), the international tax law firm L&P – Ludovici Piccone & Partners, and the experiences from the annual advanced transfer pricing courses and conferences, this first edition of the book acts as a manual for understanding transfer pricing principles and their practical application. It provides a balanced approach by first detailing the basics of transfer pricing and second proceeding to specific topics that are highly relevant in today's tax environment. For the purpose of easy understanding, the book is presented in two parts: Part I: General Topics I. Introduction to Transfer Pricing II. Accurate Delineation and Recognition of Actual Transactions: Comparability Analysis III. Transfer Pricing Methods (Part I): Traditional Transaction Methods IV. Transfer Pricing Methods (Part II): Transactional Profit Methods V. Administrative Approaches to Avoiding/Minimizing Transfer Pricing Disputes VI. Administrative Approaches to Resolving Transfer Pricing Disputes VII. Transfer Pricing Documentation: Master File, Country File and Country-by-Country Reporting Part II: Specific Topics VIII. Attribution of Profits to Permanent Establishments IX. Transfer Pricing and Intra-group Services X. Transfer Pricing and Intra-group Financial Transactions XI. Transfer Pricing and Intangibles XII. Transfer Pricing, Supply Chain Management and Business Restructurings XIII. Transfer Pricing and Customs Valuation XIV. Transfer Pricing and EU State Aid In analysing the above topics, the work undertaken by the OECD, UN, EU, World Customs Organization, World Bank, International Monetary Fund and other international organizations is considered. Moreover, the book contains several practical examples, judicial precedents and illustrative explanations to complement the understanding. The book will be a catalyst for immense learning of students and young professionals who are at the introductory stage of understanding the nuances of transfer pricing. Further, the book also caters to tax lawyers, in-house tax counsels and academics working in international organizations, the business community and advisory firms as well as government officials interested in understanding transfer pricing.
Download or read book Contributions to Education written by Columbia University. Teachers College and published by . This book was released on 1926 with total page 88 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book A Study of Sex Behavior in the White Rat by Means of the Obstruction Method written by Arthur Thomas Jersild and published by . This book was released on 1927 with total page 786 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Routine and Varying Practice as Preparation for Adjustment to a New Situation written by Leland Whitney Crafts and published by . This book was released on 1927 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Facilitation and Inhibition written by Thomas Nichols Jenkins and published by . This book was released on 1926 with total page 488 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Directoplate Corporation V Huebner Bleistein Patents Company written by and published by . This book was released on 1926 with total page 824 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Redox Active Ligands written by Marine Desage-El Murr and published by John Wiley & Sons. This book was released on 2024-02-05 with total page 373 pages. Available in PDF, EPUB and Kindle. Book excerpt: Redox-Active Ligands Authoritative resource showcasing a new family of ligands that can lead to better catalysts and promising applications in organic synthesis Redox-Active Ligands gives a comprehensive overview of the unique features of redox-active ligands, describing their structure and synthesis, the characterization of their coordination complexes, and important applications in homogeneous catalysis. The work reflects the diversity of the subject by including ongoing research spanning coordination chemistry, organometallic chemistry, bioinspired catalysis, proton and electron transfer, and the ability of such ligands to interact with early and late transition metals, lanthanides, and actinides. The book is divided into three parts, devoted to introduction and concepts, applications, and case studies. After the introduction on key concepts related to the field, and the different types of ligands and complexes in which ligand-centered redox activity is commonly observed, mechanistic and computational studies are described. The second part focuses on catalytic applications of redox-active complexes, including examples from radical transformations, coordination chemistry and organic synthesis. Finally, case studies of redox-active guanidine ligands, and of lanthanides and actinides are presented. Other specific sample topics covered include: An overview of the electronic features of redox-active ligands, covering their historical perspective and biological background The versatility and mode of action of redox-active ligands, which sets them apart from more classic and tunable ligands such as phosphines or N-heterocyclic carbenes Preparation and catalytic applications of complexes of stable N-aryl radicals Metal complexes with redox-active ligands in H+/e- transfer transformations By providing up-to-date information on important concepts and applications, Redox-Active Ligands is an essential reading for researchers working in organometallic and coordination chemistry, catalysis, organic synthesis, and (bio)inorganic chemistry, as well as newcomers to the field.
Download or read book The Prognostic Values of Certain Groupings of the Test Elements of the Thordike Intelligence Examimnation for High School Graduates written by David Welty Lefever and published by . This book was released on 1928 with total page 438 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Group Cohomology and Algebraic Cycles written by Burt Totaro and published by Cambridge University Press. This book was released on 2014-06-26 with total page 245 pages. Available in PDF, EPUB and Kindle. Book excerpt: Group cohomology reveals a deep relationship between algebra and topology, and its recent applications have provided important insights into the Hodge conjecture and algebraic geometry more broadly. This book presents a coherent suite of computational tools for the study of group cohomology and algebraic cycles. Early chapters synthesize background material from topology, algebraic geometry, and commutative algebra so readers do not have to form connections between the literatures on their own. Later chapters demonstrate Peter Symonds's influential proof of David Benson's regularity conjecture, offering several new variants and improvements. Complete with concrete examples and computations throughout, and a list of open problems for further study, this book will be valuable to graduate students and researchers in algebraic geometry and related fields.
Download or read book The Cognitive Neuroscience of Memory written by Amanda Parker and published by Psychology Press. This book was released on 2005-08-18 with total page 698 pages. Available in PDF, EPUB and Kindle. Book excerpt: Recent advances in techniques available to memory researchers have led to a rapid expansion in the field of cognitive neuroscience of memory. This book provides accessible coverage of four key areas of recent advance, including research on functional imaging, electrophysiological and lesion studies, and developments from the computational modelling approach. The first section reviews functional imaging studies in humans, with particular emphasis on how imaging methods have clarified the cortical areas involved in memory formation and retrieval. The second section describes electrophysiological and lesion research in monkeys, where lesion and disconnection studies are rapidly adding to our knowledge of both information processing and modulatory aspects of memory formation. In the third section, electrophysiological and lesion studies in rats are reviewed allowing for a detailed study of the role of novelty and exploration in memory formation. The final section reviews current research in computational modelling which has allowed the development of new theoretical and experimental approaches to the study of memory encoding and retrieval. This volume draws together the current developments in each field, allowing the synthesis of ideas and providing converging evidence from a range of sources. It will be a useful resource for both advanced undergraduate and postgraduate students of psychology, as well as researchers in the field and anyone with an interest in cognitive neuroscience.
Download or read book Studies written by University of Southern California and published by . This book was released on 1928 with total page 426 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Columbia University Contributions to Philosophy and Psychology written by Columbia University and published by . This book was released on 1915 with total page 346 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Railway Signaling and Communications written by and published by . This book was released on 1957 with total page 920 pages. Available in PDF, EPUB and Kindle. Book excerpt:
