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OECD Transfer Pricing

These country profiles focus on countries’ domestic legislation regarding key transfer pricing principles, including the arm’s length principle, transfer pricing methods, comparability analysis, intangible property, intra-group services, cost contribution agreements, transfer pricing documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures. View the OECD Profiles.

To read more about Transfer Pricing, visit the GLOBESTRATEGY Post here .

Transfer Pricing

Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length’. According to Rogers and Oats (2022), ‘The arm’s length principle (ALP) is the basis of the tax transfer pricing rules in most
countries and is used to determine an arm’s length transfer price: the price that would be used if the same transaction were undertaken by unrelated third parties’.

Transfer pricing can be used as global strategic intervention for companies’ to shift income of one affiliate to another affiliate located in an overseas jurisdiction’ ‘to maximize firm value using their international business structure’ ( Yoo, 2020).


Further Open resources on Transfer pricing
Rogers, H., & Oats, L. (2022, January). Transfer pricing: changing views in changing times. In Accounting Forum (Vol. 46, No. 1, pp. 83-107). Routledge.

Yoo, J.S., 2022. The effects of transfer pricing regulations on multinational income shifting. Asia-Pacific Journal of Accounting & Economics29(3), pp.692-714.

International trade and Business through the movies.

A list of films that signpost you to key topics in International trade and global business can be viewed on Introglobalstudies.

1. The deceptive promise of free trade

“When it comes to global trade, it would seem that trickery, threats and deception are the order of the day – yet all this takes place largely beyond the reach of the public eye. Donald Trump has made “America First” his agenda and rallying cry. Along with aiming sharp criticism at global export champion Germany, Trump has also introduced punitive tariffs and warned of further measures. Will this fresh wave of protectionism lead to economic isolationism and threaten global free trade? And what about those for whom free trade’s promise of prosperity increasingly rings hollow? Around the world, many people have come to regard themselves as the losers of globalization. If the true winners of free trade and globalization are not ordinary citizens, has the time come to revise the liberal orthodoxy of free trade? This documentary visits Germany, Switzerland, the United States and Cameroon to explore these issues by way of some everyday examples, including the trade in onions, floor tiles, and bicycles.”

96 hours of happiness. A billion people celebrating

Over 1 billion people will take time off in a 96 hour period from Thursday, Apr 13, 2023  to Sunday, Apr 16, 2023 to celebrate with friends and family. 96 hours of reflection on living, while also connecting and renewing their cultural heritage.  These people will also take time away from their daily lives, to engage with the paraphernalia of divinity, thanking a plethora of deities and seeking forgiveness for the 8760 hours of sinful transactions and pleasures, Some will thank the earth for a bountiful harvest, and others might engage in moral ruminations. They will of course also gourmandise their way into an elusive search for happiness.

Most importantly, these 96 hours will be largely a peaceful celebration for these people.

What are they celebrating?

285 million Bengali people will celebrate Pohela Boishakh as the first day of the Bengali calendar which is also the official calendar of Bangladesh from Fri, Apr 14, 2023 

220 million eastern orthodox christians will celebrate Easter on Sunday, April 16. Eastern Christianity recognises a different date for Easter because it typically follows the Julian calendar. The Julian Calendar was first proposed by Julius Caesar in 46BC. The year in this calendar consisted of 365 days, with every fourth year having 366 days.

77 Million Tamils will celebrate “ Fri, Apr 14, 2023 as the Tamil New Year, or the first day of year on the Tamil calendar, traditionally celebrated as a festival by Tamils as the first day of the Tamil month Chittirai.

73 million Maithils,living in India and Nepal celebrated Jur Sital or Maithil New Year on Fri, Apr 14, 2023. Jur Sital  is the celebration of the first day of the Maithil new year also called Aakhar Bochhor. The festive occasion is in keeping with the Tirhuta Panchang calendar used in the Mithila region.

72 million Thais and Malaysian Siamese people started celebrating Songkran from Thu, Apr 13, 2023 – Sat, Apr 15, 2023. The word “Songkran” comes from the Sanskrit word saṃkrānti,mliterally “astrological passage”, meaning transformation or change.

57 million Burmese will celebrate Thingyan or the Burmese New Year festival from Thu, Apr 13, 2023 to  Sun, Apr 16, 2023. Commonly referred to as the Water Festival, Maha Thingyan allows people to celebrate the Burmese New Year.

26 million Nepalese will celebrate Nepalese New Year or Navavarsha  on Fri, Apr 14, 2023. This is based on Nepal Sambat, also spelled as Nepala Sambata, is the lunisolar calendar used by Nepali of Nepal.

44 million Odia people celebrated Pana Sankranti on Fri, Apr 14, 2023. This festival is also known as Maha Bishuba Sankranti and  is the traditional new year day festival of Odia people in Odisha, India.The festival occurs in the solar Odia calendar (the lunisolar Hindu calendar followed in Odisha) on the first day of the traditional solar month of Meṣa.

40 million Malayalis will celebrate “Vishu” marking the first day of the malayalam astronomical year on Sat, Apr 15, 2023.Vishu falls on the first day of the month of Medam in the Malayalam Calendar] (which is around April 14 or 15 in the Gregorian calendar).

36 million Assamese people will mark Bohag Bihu as the beginning of the Assamese New Year from Friday, 14 April 2023 for seven days. Bohag Bihu or Rongali Bihu also called Xaat Bihu or the seven Bihus) is a traditional ethnic festival celebrated in the Northeastern Indian state of Assam and other parts of Northeastern India by the indigenous ethnic groups of Assam.

33 million Khamti, Singpho, Tangsa, Khamyang Tai Phake, Tai Aiton people, started celebrating the Sangken festival  from Thu, Apr 13, 2023 to Sat, Apr 15, 2023. Sangken is celebrated in Arunachal Pradesh and parts of Assam, India, as the traditional New Year’s Day from 14 to 16 April by the Theravada Buddhist Communities. Sangken generally falls in the month of ‘Nuean Ha’, the fifth month of the year of the Tai lunisolar calendar coinciding with the month of April.

26 million Sikhs started celebrating Vaisakhi on Friday, 14 April 2023, to mark the first day of the month of Vaisakh.Vaisakhi is also the date for the Indian Solar New Year.

2.5 million Dogras will also celebrated Vaisakhi on Friday, 14 April 2023 as the first month of the Shastra Samvat or  Dogra-Pahari Calendar.

17 Million Sinhalese celebrated  Aluth Avurudda on Fri, Apr 14, 2023 which is the first day of the month of Bak, which represents prosperity in the Sinhalese calendar (or in the month of April according to the Gregorian calendar.

19 million Khmer people celebrate Cambodian New Year o.r Khmer New Year from Fri, Apr 14, 2023 – Sun, Apr 16, 2023. This period is also celebrated as Choul Chnam Thmey and Moha Sangkranta.

22 million Lao people started celebrating Lao New Year, also called Pi Mai or less commonly Songkran (in Lao language)  from Fri, Apr 14, 2023 till Sun, Apr 16, 2023.

15.3 million Jewish people will end the 7 or 8 day festival of Pesach on Thu, Apr 13, 2023, commemorating the Hebrews’ liberation from slavery in Egypt and the “passing over” of the forces of destruction.

8 million Dai people will celebrate The Water-sprinkling festival, a traditional festival of the to mark the Solar New Year. from Thu, Apr 13, 2023 to Sat, Apr 15, 2023.

1.2 million Tripuri people started celebrating the Buisu new year festival in Bangaldesh and Indian state of Tripura from Thursday Apr 13, 2023 This three-day festival coincides with the Bengali New Year’s Day and runs from April 13th to 15th each year, The  three consecutive days are ‘Hari Buisu’, ‘Buisu’, ‘Bisikwtal’. The first day of the festival is called as ‘Hari Buisu’, and is dedicated to the domestic animals.

1.8 million ​​Tulu people celebrate Bisu Parba on Sat, Apr 15, 2023, marking the first day of Paggu, which is the first month of the Tulu calendar. It falls in the middle of April in the Gregorian calendar, on 14 or 15 April every year.

948,000  Chakma people celebrated Fri, Apr 14, 2023  as the traditional New Year’s Day .

55,000 Bodo people celebrated the Bwisagu festival at the beginning of the first month of the Boro year, around mid-April.The Bodos call this popular festival as Bwisagu, which means the start of the new year. This Bwisagu festival is observed at the starting part of the first month of the Assamese year.

Sources:
https://en.wikipedia.org/wiki/Sinhalese_people

https://www.heritagefoundation.org.in/current-issue/single/eyJpdiI6IjBEYnVoTDdlYkl6eHdDWEJ6ckphSlE9PSIsInZhbHVlIjoiL2FQZVBjcEt1aE1XUXlxMmg2QjVRQT09IiwibWFjIjoiZWNlY2U1YzM2NjE5Zjg3NmVlYTQyMzM5OTdlMjI4NWRiYmFkMWQzYjRhM2NhZjVmN2QwNGZiZTllNzYwYWEyOCJ9

https://www.britannica.com/topic/Passover

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