A Study on Arm's Length Methods-A Case of America And its Implications for Legislation of Economic Substance Doctrine in Taiwan
碩士 === 中國文化大學 === 法律學系 === 105 === Due to the globalization and the difference of taxation from countries, MNEs’ tax avoidance about transfer pricing of intangible property is becoming one of the most important issue for international taxation. This thesis will introduce a case of transfer pricing o...
| Main Authors: | , |
|---|---|
| Other Authors: | |
| Format: | Others |
| Language: | zh-TW |
| Published: |
2017
|
| Online Access: | http://ndltd.ncl.edu.tw/handle/5b4wae |
| Summary: | 碩士 === 中國文化大學 === 法律學系 === 105 === Due to the globalization and the difference of taxation from countries, MNEs’ tax avoidance about transfer pricing of intangible property is becoming one of the most important issue for international taxation. This thesis will introduce a case of transfer pricing of intangibles of Taiwan and similar cases of America and action plan of OECD , then try to find out the way to determine transfer pricing of intangibles with arm's length method under economic substance principle. In the last chapter, this thesis will provide suggestions for Taiwan taxation law about transfer pricing of intangibles.
|
|---|