Transfer pricing by the Canadian oil industry: a company analysis

1996 ◽  
Vol 3 (5) ◽  
pp. 333-340 ◽  
Author(s):  
Jean-Thomas Bernard ◽  
Eric Genest-Laplante
Keyword(s):  
Transfer Pricing ◽  
Oil Industry ◽  
A Company ◽  
Company Analysis

scholarly journals Sustainable Oil and Profitable Wind

2017 ◽  
Vol 38 (2) ◽  
pp. 79-96 ◽  
Author(s):  
Jochen Hoffmann ◽  
Maria E. Kristensen
Keyword(s):  
Process Model ◽  
Oil Industry ◽  
Public Perceptions ◽  
Public Communication ◽  
The Public ◽  
Corporate Learning ◽  
Constitutive Process ◽  
Downward Spiral ◽  
Social And Environmental Responsibilities ◽  
A Company

Abstract Companies are confronted with differing public perceptions, which influence the way in which they present their social and environmental responsibilities. Our qualitative study compares the online responsibility communication of two companies from the energy sector: Shell, representing the controversial but profitable oil industry; and Vestas, representing the sustainable wind industry, the financial competitiveness of which is sometimes called into question. The website analysis reveals that both companies engage in inverted positioning. They invert perceived weaknesses into strengths: Shell highlights its social and environmental responsibilities, whereas Vestas, instead of capitalising on its potential as a CSR brand, highlights its economic responsibility. Theoretically, we integrate inverted positioning into a constitutive process model of responsibility communication. Inverted positioning might lead either to a reputational downward spiral, making a company less credible in the longer term, or the public communication of contested responsibilities functions as a self-imposed ambition that can, over time, induce substantial corporate learning processes.

Transfer Pricing and Location of Intangibles - Spillover and Tax Avoidance through Profit Shifting

2020 ◽  
Author(s):  
Rebecca Reineke ◽  
Katrin Weiskirchner-Merten
Keyword(s):  
Empirical Evidence ◽  
Transfer Pricing ◽  
Home Bias ◽  
Tax Avoidance ◽  
Optimal Location ◽  
The Other ◽  
Profit Shifting ◽  
Tax Rate ◽  
Length Range ◽  
A Company

This study examines how spillovers affect a multinational company's choice of an intangible's location and the corresponding transfer price for using this intangible. Our model uses a company with a domestic division in a high-tax country and a foreign division in a low-tax country, where each division's activities generate spillovers on the other division's income. In contrast to previous studies, our analysis incorporates an intangible's optimal location when the company trades off tax minimization and efficient activities. By locating the intangible abroad, the company reduces its tax liability, whereas locating the intangible domestically yields more efficient domestic division activities. For a high spillover of the domestic division, the company locates the intangible domestically. Our model supports empirical evidence regarding intangibles' location that is interpreted as "home bias". Additionally, we show how variations in regulatory parameters-arm's length range and tax rate differential-affect the divisions' activities and the intangible's location.

scholarly journals Company Analysis – The Beginning Step for Scholarly Research

2017 ◽  
pp. 1-18 ◽  
Author(s):  
P. S. Aithal
Keyword(s):  
Business Case ◽  
Management Research ◽  
Scholarly Research ◽  
Case Study Methodology ◽  
Research And Teaching ◽  
Challenges And Opportunities ◽  
Study Methodology ◽  
A Company ◽  
Company Analysis

Company analysis is the important type of case method in Research Methodology and is commonly used by the beginners of scholarly research. A case study based management research and teaching pedagogy are adopted by many business schools with the belief that it is a most powerful way to study and learn new lessons required to identify, understand, and solve the problems in the process of managing and leading the organizations. Developing a business case on various managing aspects of a company and analysing case forces students to grapple with exactly the kinds of situations, decisions, and dilemmas managers confront every day. Company analysis is a powerful tool in developing both research case study and teaching case study in business management subject. Compared to industry analysis, company analysis gives focused and deeper insight into a company and its business in terms of challenges and opportunities. In this paper, we have discussed the procedure of writing company focussed case study based on a newly developed company analysis framework. We also recommend the Company analysis as a class of case study methodology in management research for the beginners and budding researchers as a beginning step in scholarly research.

scholarly journals PENGARUH PAJAK DAN TUNNELING INCENTIVE TERHADAP INDIKASI MELAKUKAN TRANSFER PRICING (STUDI KASUS PADA PERUSAHAAN LQ-45 YANG TERINDEKS DI BURSA EFEK INDONESIA)

2021 ◽  
Vol 7 (1) ◽  
pp. 1
Author(s):  
Silma Taqiya Maulani ◽  
Ismet Ismatullah ◽  
Rinaldi Rinaldi
Keyword(s):  
Ownership Structure ◽  
Sampling Method ◽  
Stock Exchange ◽  
Transfer Pricing ◽  
Purposive Sampling ◽  
Incentive Variable ◽  
A Company ◽  
Majority Shareholder

ABSTRAKSalah satu indikasi perusahaan melakukan transfer pricing adalah menginginkan laba yang tinggi dengan membayar pajak yang rendah. Struktur kepemilikikan juga mempengaruhi manajemen untuk mengalihkan kekayaan kepada mereka sendiri atau pemegang saham mayoritas. Penelitian ini bertujuan untuk meneliti pengaruh pajak dan tunneling incentive terhadap indikasi melakukan transfer pricing pada perusahaan LQ 45 yang terindeks di  Bursa Efek Indonesia. Sampel penelitian yang digunakan dalam penelitian ini adalah perusahaan LQ-45 yang terdaftar secara konsisten selama periode 2015-2019 dengan metode purposive sampling. Hasil dari penelitian ini menunjukkan bahwa pajak tidak berpengaruh signifikan terhadap indikasi transfer pricing, sementara tunneling incentive berpengaruh signifikan terhadap transfer pricing. Hal ini dibuktikan dengan nilai probabilitas 0.05 lebih kecil nilai probabilitas variabel pajak atau 0,05 < 0,13. Sementara nilai probabilitas 0.05 lebih besar dari nilai probabilitas variabel Tunneling incentive atau 0,05 > 0,01. Kata Kunci : Pajak, Tunneling Incentive, Transfer Pricing ABSTRACTOne indication of a company doing transfer pricing is wanting high profits by paying low taxes. The ownership structure also influences management to transfer wealth to themselves or the majority shareholder. This study aims to examine the effect of taxes and tunneling incentives on indications of transfer pricing on LQ 45 companies indexed on the Indonesia Stock Exchange. The research sample used in this study was LQ-45 companies that were consistently registered during the 2015-2019 period with the purposive sampling method. The results of this study indicate that taxes have no significant effect on transfer pricing indications, while tunneling incentives have a significant effect on transfer pricing. This is evidenced by the probability value of 0.05 which is smaller than the probability value of the tax variable or 0.05 < 0.13. While the probability value of 0.05 is greater than the probability value of the Tunneling incentive variable or 0.05 > 0.01.                                               Keywords: Tax, Tunneling Incentive, Transfer Pricing

scholarly journals The influence of international offshore jurisdictions on the pricing strategy

VUZF Review ◽  
2021 ◽  
Vol 6 (4) ◽  
pp. 79-90
Author(s):  
Оlena Chukurna ◽  
Larysa Radkevych ◽  
Liliya Rudyk
Keyword(s):  
Transfer Pricing ◽  
Pricing Strategy ◽  
Pricing Mechanism ◽  
Pricing Process ◽  
Transfer Prices ◽  
National Economies ◽  
The Impact ◽  
The Relationship ◽  
A Company

The article analyzes the causes of offshore jurisdictions and identifies the effects of offshore on national economies. An analysis of the implementation of export-import operations carried out by offshore companies in order to influence the pricing process. The pricing mechanism with affiliates within offshore jurisdictions was presented. It was substantiated the role of offshore banks in the implementation of the pricing mechanism. It was presented the pricing mechanisms within offshore jurisdictions. It has been made an analysis of the impact of transfer pricing within offshore jurisdictions. It was substantiated the economic mechanism of pricing. The international experience of regulation of offshore jurisdictions and the system of controlling the operations of affiliates was analyzed. It was substantiated the mechanisms of functioning of offshore zones and companies operating in offshore jurisdictions. The relationship between agreements concluded within offshore jurisdictions in the following areas is established and substantiated: the agreement is concluded between two independent companies in case of underpricing; the agreement is concluded between the companies connected with the capital relations (affiliated companies) at understatement of the price; agreements between two independent companies in case of overpricing; agreements between affiliated companies in case of overpricing. It was justified the use of the transfer pricing mechanism within offshore jurisdictions. Transfer prices allow you to withdraw capital from the country, as well as hide the profits of companies from taxation. The following ways of minimizing taxation are systematized: registration of a company that concentrates profits in a jurisdiction with lower taxation; concentration of profits in companies that are unprofitable according to management accounting; the use of front companies as sales companies in which profits are concentrated; non-payment of taxes as a result of illegal liquidation of the enterprise - the taxpayer, where the profit is concentrated. The basis of tax minimization is the use in the transaction of a price that deviates from the market.

scholarly journals ABCD Analysis as Research Methodology in Company Case Studies

2017 ◽  
pp. 40-54 ◽  
Author(s):  
P. S. Aithal
Keyword(s):  
Research Methodology ◽  
Case Analysis ◽  
Analysis Framework ◽  
Affecting Factors ◽  
Critical Elements ◽  
New Information ◽  
Analysis Technique ◽  
A Company ◽  
Company Analysis

Company analysis is a type of Case Study method among many types of Case study based Research Methods. While developing a Company Case study based on various issues in Management, the researcher can choose any company of any industry to study an issue or to solve a problem. Usually, a case analysis ends up with the observation of new performance pattern, interpretation of issues in the form of new information, or development of new suggestions to improve the system or to solve the problems optimally. Company analysis is considered to be a most powerful method to study new lessons required to identify, understand, and solve the problems in the process of managing and leading the organizations. Analysing business issues related to a company provides an opportunity to researchers to identify the kinds of situations, decisions, and dilemmas managers facing every day. Company analysis is a powerful tool in developing both research case study and teaching case study in business management subject. In this paper, we have discussed how ABCD Analysis as Research Methodology in company case analysis procedures in order to help the budding researchers while developing and analysing Company analysis as a Case study. In this paper, we have checked whether ABCD (Advantages, Benefits, Constraints, and Disadvantages) analysis framework can be used while analysing a company, how to consider various determinant issues of a company, selecting various affecting factors under these issues and identifying constituent critical elements for each construct using its elemental analysis technique, and the reasons to recommend the ABCD analysis framework in any kind of company analysis.

Oil

2017 ◽  
Author(s):  
Angela Penrose
Keyword(s):  
Transfer Pricing ◽  
Petroleum Industry ◽  
Tax Avoidance ◽  
Oil Industry ◽  
Political Sovereignty ◽  
International Firm ◽  
Resources And Capabilities ◽  
Oil Crisis ◽  
The Impact ◽  
Trade And Investment

The chapter covers Edith’s research into the oil industry and multinational companies, and the rise of the Organization of Petroleum Exporting Countries, including publication of The Large International Firm in Developing Countries (1968), which challenged the traditional theories of international trade and investment as they applied to the oil industry. She was the first to discover the significance of transfer pricing and tax avoidance. She started seminars on the international petroleum industry with Peter Odell and later with Robert Mabro, at St Anthony’s College, Oxford. Edith travelled extensively, analysing the impact of multinationals on the economic welfare of the countries in which they operated, focusing on the efforts made by governments to retain as much as possible of their economic and political sovereignty, while still benefiting from the resources and capabilities of foreign investors. By the time of the ‘oil crisis’ of 1973 she was considered one of the top oil economists in the world.

Microsoft's Foreign Earnings: Tax Strategy

2015 ◽  
Vol 30 (4) ◽  
pp. 297-310 ◽  
Author(s):  
Larissa S. Kyj ◽  
George C. Romeo
Keyword(s):  
Multinational Corporations ◽  
Transfer Pricing ◽  
Corporate Tax ◽  
Tax Havens ◽  
Tax Rate ◽  
Foreign Earnings ◽  
Microsoft Corporation ◽  
A Company ◽  
Foreign Corporation ◽  
The U.S

ABSTRACT The high corporate tax rate and the complexity of the U.S. tax code provide U.S. multinationals with the incentives and opportunities to shift income to foreign low-tax jurisdictions. In theory, U.S. corporations are taxed at the statutory rate of 35 percent on their worldwide income, but income earned by an active Controlled Foreign Corporation (CFC) is usually not taxed until it is repatriated to the parent company in the U.S. As a result, trillions of dollars in cash and investments sit in offshore companies, awaiting a repatriation tax holiday. Much of these earnings are held by technology companies. The case looks at Microsoft Corporation, a company with $60.8 billion in unrepatriated earnings as of 2012. The case considers tax havens, nonrepatriation of earnings, cost-sharing arrangements, and transfer pricing and is intended to expose students to the subtleties and complexities of corporate tax strategies. Although the case is set in 2012, the goal of the case is to demonstrate to the students the complex environment in which multinational corporations operate and is independent of any particular tax regime.

Petrobras Operational Excellence Programme

2002 ◽  
Author(s):  
Carlos Tadeu da Costa Fraga ◽  
Carlos Ferraz Mastrangelo
Keyword(s):  
Oil Industry ◽  
Lessons Learned ◽  
Business Unit ◽  
Design Procedures ◽  
Commission Report ◽  
Offshore Oil Industry ◽  
Operational Excellence ◽  
Offshore Oil ◽  
A Company ◽  
Widespread Dissemination

This paper addresses actions implemented by Petrobras after the P-36 accident. The purpose of investigations following major accidents is to understand what exactly happened to avoid repetition. It is everyone’s responsibility to adopt practices that mitigate the risks even more in any activities. The P-36 accident was therefore analysed and discussed as transparently and deeply as possible in order that the lessons learned may be translated into safer operations. This is how it is done throughout the oil industry: the lessons learned from major accidents usually cause radical changes to the industry’s practices with regard to change in equipment, design, procedures, behaviours and attitudes. The P-36 Investigation Commission, with technical experts from Petrobras, universities and worker union representatives, audited by a company of international repute, produced several recommendations and identified areas for improvement. This paper discusses how Petrobras considered the commission report and how the areas for improvement are to be addressed. Many recommendations were immediately applicable but others, including some areas for improvement, requiring more detailed planning, were included in an Operational Excellence Programme (PEO – Programa de Exceleˆncia Operacional). This Programme shall be applied to every offshore unit of the company, while taking into account the peculiarities of each Business Unit. This Programme covers actions involving Petrobras design practices, operation, ballast and stability, maintenance, safety and human resources for offshore units and all those actions shall be concluded by December 2002. A detailed description of the actions which go beyond those required by current legislation will also be given, permitting Petrobras to achieve operational excellence in all its offshore units. Furthermore, Petrobras intends to contribute to the ongoing improvement of offshore oil industry practices through widespread dissemination of this Programme, which has already begun.

Transfer pricing as a company management tool

2021 ◽  
pp. 49-72
Author(s):  
Elena Avtukhova
Keyword(s):  
Transfer Pricing ◽  
Management Tool ◽  
State Agencies ◽  
Real Economy ◽  
Management Mechanism ◽  
Management Tools ◽  
Foreign Companies ◽  
Efficient Management ◽  
The Russian Federation ◽  
A Company

This article studies one of the most complicated and yet popular company management tools, the transfer pricing. The author considers the aims and purpose of transfer pricing, the formation of a transfer pricing system as a company management tool, popular viewpoints on transfer price calculation methodologies, strengths and weaknesses of the existing approaches, and offers a hypothesis on transforming transfer pricing methods. The paper systematizes transfer pricing methods with due regard to the experience of domestic and foreign companies, the development of the Russian Federation legislation, the recommendations of the OECD, and the studies of auditing and consulting companies. The author presents an overview of the most popular transfer pricing methods which serve as a basis for using one or another method, identifies the factors of efficient management mechanism. The article analyses the specific features of using a particular management mechanism in financial companies and companies operating in real economy, studies the methodology to deploy transfer pricing in a legal entity and within a vertically integrated holding. Taking into account the fact that regulation of transfer pricing is also a tax regulation tool used by the state, the author emphasizes that the problems of transfer pricing tools aimed at tax risk management are not the object of the article. The results of the study can be used by employees and executives of corporate financial divisions, analysts, consultants, and employees of state agencies and authorities while developing the methodology for using financial instruments in company management.

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