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80 Uppsatser om Transactions - Sida 2 av 6

Dokumentationskrav vid internprissättning : En analys av lagförslagen till svenska dokumentationsregler i propositionen 2005/06:169

According to the arm?s length principle, Transactions between associated multinational en-terprises (MNE) shall be based on the same conditions as Transactions between unrelated parties. This means that intra-group prices on cross-boarding Transactions must be at arm?s length range and consistent with conditions in the open market. The arm?s length principle is expressed in article 9.1 of the OECD Model Tax Convention and Chapter 14 section 19 of the Swedish Income Tax Act.When transfer pricing between associated MNEs is not reflecting the arm?s length princi-ple, states face the possibility of losing tax revenue.

Internprissättning : Bevisbörda, dokumentationskrav och rättssäkerhet

As the globalization of companies increases day by day, the need for a clear and comprehensible legislation to overcome the problems with transfer pricing Transactions increases as well. Incorrect pricing in transfer pricing situations between companies with close economic ties to each other makes countries risk parts of their taxation income.Swedish legislation uses the internationally accepted arm?s length principle to regulate the transfer pricing Transactions. Through the correction rule, the rule is upheld that the pricing between two companies with close economic ties to each other must apply to the same conditions as it would have been if it was between two companies without close economic ties to each other.To ensure that enough material is provided to base the assumption whether or not the correction rule has been followed or not, Swedish legislation provides a number of paragraphs to regulate the matter. The legislation is spread all over and is hard to interpret.

Beskattning av skalbolagstransaktioner : Analys av skalbolagsreglerna ur ett tillämpnings- och rättssäkerhetsperspektiv

Shell companies are characterized by containing liquid assets such as cash, securities or other similar assets. Transactions of shell companies constitutes a severe problem since the purchaser often has the aim of obtaining undue tax advantages by not paying the tax debt of the company.Historically it has been complicated for the legislator to stop the set-up in an efficient way since the Transactions as such are not illegal, instead rather commonly used for example to restructure companies or for the transfer of companies to the younger generation. The purpose of the current legislation is to prevent individuals and corporations to involve in shell company trade. Aiming for an efficient legislation, the tax rate is at a very high level.The issue with the rules is that also honest buyers are at risk of being covered. This calls for high demands in complying with the principle of legal certainty and the possibility to forecast the tax consequences.The purpose of the thesis is to identify and analyze eventual problems when applying the legislation.

Värdepapperisering i Sverige : Finns det en marknad?

As of today, securitization is an established product on the capital market. The first transaction was made in the US in the 1970s. Since then the product has been developed and today there are several different structures of the product. Internationally securitization has been used for two reasons. Originally securitization was used to gain capital relief, but since capital requirements such as Basel II were implemented, the usage of securitization changed to more of a funding source.

C-7/13 Skandiamålet : En analys av hur Skandiama?let pa?verkar art. 11 merva?rdesskattedirektivet anga?ende merva?rdesskattegrupper

In September 2014 the ECJ issued its decision in C-7/13 the Skandia case. The case con- cerned service Transactions made between a main establishment in a third country and its Swedish branch. The branch was a member of a VAT group in Sweden. The ECJ estab- lished that the membership resulted in that the VAT group was considered as one taxable person which meant that the services was considered provided to the group itself and not the separate member. Therefore the Transactions were deemed taxable.

Implementering av verksamhetsbaserad arkivredovisning i statliga museimyndigheter

The  change that has occurred during the past few decades concerning the development of electronic records, information technology and the constantly increasing quantity of information, have confronted the archival discipline with new challenges. In the digital world, the concept of ?record? has changed from representing something lasting and physical to something much more abstract and transient. The way to approach archival description has also changed, from focusing on the static preservation of archival records, to documenting the Transactions of organisations, and to clarify operational processes. The discussion about the general purpose of the archival discipline, and its place in a changing world, has led to a new approach to archival description.

Ränteavdrag i företagssektorn : - Skatteverkets förslag till förändring

In Sweden the main principle is that interest expenses are deductable. The rules of limitations on interest deduction are exemptions to this main principle. The provisions, which came into force on the first of January 2009, have been inserted into Chapter 24 secs. 10 a ? e Swedish Income Tax Act (ITA).

The Future of ABC at Sandvik Tooling

Abstract Title: The Future of ABC at Sandvik Tooling ? Incorporating ABC with information systems in order to drive business development from a cost point of view. Authors: Jenny Andersson and Camilla Salomonsson. Supervisor: Charlotta Johnsson ? Department of Automatic Control, Lund University.

A/B-testning av Mikrotransaktioner

Mikrotransaktioner är en stor del av dagens internethandel. Det används flitigt på både websidor och i datorspel. Denna rapport tar upp hur ett företag eller en privatperson kan, genom A/B-testning, testa vilken transaktionstyp som är bäst för just deras applikation. Problemet är att det finns många olika transaktionstyper att välja mellan och att det inte finns något bra sätt att få fram vilket som är det bästa för just din applikation. För att försöka hitta den optimala transaktionstypen utnyttjades en testapplikation med olika transaktionstyper.

Företagsförvärv: En studie av redovisningsdatas inverkan på förvärvspremien

Although previous research conclude that mergers and acquisitions do not always lead to improved profitability or increased shareholder return, the number and size of M&A?s is steadily increasing. In this thesis we examine why an acquirer pays a price higher than the market value. Can accounting data explain the size of the premium? 618 European Transactions between 1997 and 2008 are examined and relationships between the targets? accounting data and the premium is analysed through statistical regressions.

Värdeskapande i Leveraged Buyouts i jämförelse med noterade företag

The purpose of this thesis is to study the difference in value generation and its drivers between leveraged buyouts and listed companies. The primary objective is to observe if differences exist. A secondary objective is to understand the differences and attempt to provide an explanation based on earlier research on Private Equity. A selection of large Swedish LBO-Transactions, carried out between 1998 and 2012, are analyzed and their value generation drivers subject to comparison with a weighted index of companies listed on the Nasdaq OMX Stockholm. A clear difference in value creation is observed, both in size and composition.

Att skapa grunden tillkassasystemsapplikationer för Android : Undersökande arbete samtimplementation

This paper was made together withTechPay AB, by their request.The dissertation has been divided into two separate parts; one of which is fully theoretical, with the focus on the security requirements of a digital cash register, and how to meet these requirements.The second part covers the implementation of anAndroid-oriented Java-library,created with help from the security requirements found in the first part. The purpose of this library is to make it easier to develop a cash register that uses payment terminals from TechPay.This paper also covers different communication protocols, encryption techniques and recommendations from authorities, banks and Android. This paper also contains a small review of how users are validated in applications on the current market that handles money Transactions..

Kvalitativ analys av Holmen Skogs internprissättningsmodell :

Transfer pricing has attracted considerable interest among tax authorities in recent years. One of the reasons for this is that various countries have now begun to protect their own tax bases to a greater extent than they did in the past. Sweden has introduced a law on the documentation on the grounds that the tax office to review the pricing of Transactions that occur within multinational corporations. The purpose of the law is that companies should apply a transfer pricing that meet arm's length principle, which means that internal pricing reflects market prices. The EU Commission has, together with the EU member states formed a Forum, the EU Joint Transfer Pricing Forum (JTPF), since cross-border trade within groups constitute a threat to the internal market. The Forum has drawn up a code of conduct which includes a model of documentation.

Toleranszon och kundtillfredsställelse i tjänsteföretag

The aim of this thesis is to describe how service companies through adjustment of the customer?s zone of tolerance can influence customer?s perception of the service during the processes of service delivery and create customer satisfaction. The method used was case study approach utilizing personal interviews, which were conducted at two service companies. The study showed that the aspects of the service that have greatest importance for the customer?s assessment of the service and customer satisfaction among others are personal treatment and that personel behave in the way that makes the customer feel itself taken good care of and unique.

Riskkapitalbolags inverkan på risk för finansiell kris i portföljbolag: En studie av 53 transaktioner i tillverkningsindustrin

The aim of this small thesis is to investigate if the probability of business failure is higher at the time of divestment than at the time of acquisition for portfolio companies that have been subject to private equity ownership. The background for this thesis is the widespread critique aimed at private equity firms, claiming that they increase the risk in their portfolio companies. We have performed a study of 53 buyout Transactions, involving Swedish manufacturing companies, covering a time span of 13 years, from 1995 to 2007. We find evidence of an increased risk of business failure for the portfolio companies with a short forecasting horizon (within one year). The absolute increase in the sample is however small.

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