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Prague Economic Papers Vol. The subsidiaries are frequently routine units. Subsequently, the routine units receive low reward, as they perform only routine functions.

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The OECD transfer pricing guidelines support that practice to the detriment of government budgets and public by considering the routine units as the low-risk ones. This paper reviews the relevant literature and shows that the traditional view of risk and profit allocation between strategy and routine units is inconsistent with their relative risks, resp. Results of this paper enable proposal of the transfer pricing risk analysis targets and tools. Keywords: multinational enterprise , profit shifting , stakeholder.

Abu-Serdaneh, J. Transfer Pricing in Jordanian Manufacturing Companies. Jordan Journal wof Business Administration, 11 2 , — Acerbi, C. On the Coherence of Expected Shortfall. Does Entry Size Matter? Foreign-Owned Plants and Job Security. Downside Risk.

Rethinking International Tax Law

Coherent Measures of Risk. Mathematical finance, 9 3 , — Atkinson, A. Risk, Leverage and Profitability: an Industry Analysis. Multinationals and Plant Survival. Bernard, A. Risk Management in Banking.

Cross-border taxation: Transfer pricing

ISBN Black, F. The Pricing of Options and Corporate Liabilities. Wages, Profits, and Rent-Sharing. The American Economic Review, 65 2 , 74— Borkowski, S. Transfer Price Manipulation. Draining Development? Washington: World Bank, — Did Wages Reflect Growth in Productivity? Capitalism and Freedom. Chicago: University of Chicago Press.

Gemmill, G. Downside Risk and the Size of Credit Spreads. The Debate 6m. Introduction base case 8m. Optional: Introduction to symbols 2m. Interview: Prof. Kees van Raad 7m. Introduction to BEPS 7m. Reading 15 readings. Course Syllabus 5m. Welcome to Leiden University 5m. Complete our short survey 10m.

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Tips for studying online 5m. Optional: Recording - Public Accounts Committee hearing on taxation of multinational corporations 10m. Resources: Media on the international tax planning debate 1h. Required reading 30m. Recommended reading 1h. Database BEPS 10m. Video transcripts - module 1 10m. Quiz 2 practice exercises. Exercise 1 2m. Base Case 20m. Introduction to Corporate Income Tax 7m.

Taxation of corporate groups 5m. Withholding Tax 5m. Interview prof. Kees van Raad 4m. Advanced Track: Interest deductions and other financial payments 6m. Reading 5 readings. Required Reading 30m. Recommended Reading 1h. Video transcripts - module 2 30m. Optional: Local country corporate tax features survey 30m.

Quiz 4 practice exercises. Exercises 6m.

Fundamentals of Transfer Pricing Guide | Wolters Kluwer Legal & Regulatory

Exercise 4 2m. Exercise 5 2m. Design of corporate tax law systems 20m. Controlled foreign company regimes 5m.

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Hybrid mismatches 10m. Introduction to international tax law 5m. Double taxation 8m. Distributive rules 11m. Reading 7 readings. Video transcripts - module 3 30m.