Treatment of funding risk and capital financial services versus non-financial services : never the twain shall meet? Sam Sim, Akos Rigo and Dinesh Agrawal Electrónico
By: Sim, Sam T. Y
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Contributor(s): Rigo, Akos | Agrawal, Dinesh Kumar.
Material type: 
ArticlePublisher: 2020Subject(s): PRECIOS DE TRANSFERENCIA | CAPITAL | FINANCIACION | SERVICIOS FINANCIEROS
In:
International Transfer Pricing Journal v. 27, n. 4, 2020, p. 229-238Summary: Functions, assets and risks in transfer pricing mirror the classical economic factors of land, labour and capital. Famously, Thomas Piketty has written about the dominant role of capital in income equality in our age. However, from significant people's functions in 2010 to DEMPE in BEPS Actions 8-10, the recent evolution of thinking around transfer pricing has increasingly emphasized functions, i.e. labour, while relegating capital to a supporting or secondary role in the attribution of profits. The authors examine the treatment of capital in transfer pricing, comparing and contrasting between the financial services and non-financial services sectors, with the hope of contributing to a more balanced appreciation of the role of capital and the need for future guidance in this area.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2020/4-2 (Browse shelf) | Available | ITPJ/2020/4-2 |
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| ITPJ/2020/4-11 Evaluation of transfer pricing in Nigeria (2012-2020) | ITPJ/2020/4-12 Indian APA and MAP programmes | ITPJ/2020/4-13 The impact of COVID-19 on transfer pricing | ITPJ/2020/4-2 Treatment of funding risk and capital | ITPJ/2020/4-3 New draft transfer pricing legislation at a glance | ITPJ/2020/4-4 Coronavirus | ITPJ/2020/4-5 Distributors with losses |
Disponible únicamente en formato electrónico.
Resumen.
Functions, assets and risks in transfer pricing mirror the classical economic factors of land, labour and capital. Famously, Thomas Piketty has written about the dominant role of capital in income equality in our age. However, from significant people's functions in 2010 to DEMPE in BEPS Actions 8-10, the recent evolution of thinking around transfer pricing has increasingly emphasized functions, i.e. labour, while relegating capital to a supporting or secondary role in the attribution of profits. The authors examine the treatment of capital in transfer pricing, comparing and contrasting between the financial services and non-financial services sectors, with the hope of contributing to a more balanced appreciation of the role of capital and the need for future guidance in this area.
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