Suchergebnisse

Part I, ordered to be printed 20th July 1847 ; Mode of access: Internet.

This doctoral thesis deals with the tax aspects of transfer pricing. ln the context of a globalized economy where the transfer pricing policies and legislations are at stake, it raises the question whether proper instruments of regulation can be set, and if the law is the adequate tool to that end.Indeed, numerous people consider that the major disorders in the regulation of transfer pricing stem from the Arm's Length Principle itself, due to its lack of economic precision and the absence of a global authority against harmful tax competition.To address the issue, we assume that there is more to the Ann's Length Principle than its common definition. Indeed, we show that it can be considered as part of a universal law aimed at neutralizing the effects of the tax differences in the international economic exchange. Such an assumption provides for a criterium to assess the quality of national legislations as well as the relevance of the groups' transfer pricing policies.By analyzing the French legislation and case law, we show that a thorough implementation of the Ann's Length Principle implies not only to copy article 9 § 1 the convention models, but more generally to capture its content and essence by setting the conditions for a proper cooperation between actors. We also explain the relationship between the lacks in the regulation of transfer pricing and the process of setting new rules that takes place around the world, describing the rationale of the BEPS plan and of the various limitations and compliance obligations that Governments impose to the taxpayers. Lastly, we show that building a national legislation with reference to the universal Ann's Length Principle implies a true partnership between the Government and all stakeholders, paving the way to a new manner of debating the law. ; La présente thèse de doctorat porte sur la fiscalité des prix de transfert. Dans un contexte mondial propice à la remise en cause des législations et des pratiques fiscales, elle traite de la question des instruments de ...

"Serial no. 35". ; Includes bibliographical references. ; Mode of access: Internet.

AbstractLaw-making in most parliamentary democracies is dominated by the executive. Yet so far, all research has focused on the parliamentary stage of law-making. Studies suggest that the changes to bills submitted by coalition governments are the result of coalition policies dealing with the agency loss caused by ministerial drift. This is puzzling because it is already easier and more effective for coalition parties to attempt to change the bills in the executive phase than in the parliamentary one. The article aims to close the knowledge gap, and it quantitatively explores the factors that facilitate changes during the understudied executive phase on case study of the Czech Republic. Analysis reveals that government bills are altered more during the executive phase than the parliamentary phase. While we find no significant impact caused by the distance to coalition compromise, the saliency of a bill for coalition partners has a negative influence on the ratio of changes.