1. It does not take into consideration the economic synergies resulting from working as a fully economically integrated group.
2. Third party dealings (and, therefore, prices) never include similar economic synergies.
3. The cost of tangibles can be assessed as their market price can be ascertained easily but this proves ineffective when it comes to the contention regarding the transfer of Intellectual Property Rights or intangibles.
Tax haven
US Energy giant Enron for example owned 692 subsidiaries in the Cayman Islands in
2000, the year before it went bankrupt. In 1999 US-multinationals possessed 400 billion
US$ of untaxed earnings in offshore havens. By the end of 2002 the amount was about
639 billion US$. Companies for offshore purposes are now being established at the rate of around 150,000 per year. It has been estimated that nearly half本文来自辣.文,论-文·网原文请找腾讯3249'114 tax competition have been aimed at discouraging tax practices defined as “harmful” because of their ability to distort trade and investment flows, cause shifts in the distribution of the tax burden, and impose constraints on other governments’ fiscal decisions by facilitating tax avoidance. The definition of a tax haven is generally based on the following criteria;
no tax, or only nominal tax, on the relevant income;
no effective exchange of information;
lack of transparency; and absence of a requirement that substantial activities be carried on in the jurisdiction.
In response to the growing threat of the tax haven nations, the organization for economic cooperation OECD provided analytical framework for identifying jurisdictions engaged in harmful tax practices and in 1998, it notified 40 jurisdiction that were found to have
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