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Projects / Programmes source: ARIS

Influence of taxation of combined enterprises (persons) on economic concentration and on international competiting

Research activity

Code Science Field Subfield
5.05.00  Social sciences  Law   

Code Science Field
S141  Social sciences  Fiscal law 
S110  Social sciences  Juridical sciences 
Keywords
taxation, combined enterprises (persons), economic concentration, corporate and personal income tax
Evaluation (rules)
source: COBISS
Researchers (4)
no. Code Name and surname Research area Role Period No. of publicationsNo. of publications
1.  15693  PhD Aleš Kobal  Law  Researcher  2002 - 2004  267 
2.  03222  PhD Franc Pernek  Law  Head  2002 - 2004  725 
3.  19070  MSc Uroš Rožič  Law  Researcher  2002 - 2004  58 
4.  19470  PhD Bojan Škof  Law  Researcher  2002 - 2004  544 
Organisations (1)
no. Code Research organisation City Registration number No. of publicationsNo. of publications
1.  0592  University of Maribor, Faculty of Law  Maribor  5089638015  11,327 
Abstract
Slovenian Tax authority will have to respond on even bigger liberalisation of economic conditions, on expected increase of foreign investments and on increased economic operations of Slovenian Enterprises in foreign countries (especially in South – East Europe) by reworking tax legislation in taxation of combined Persons and Multinational Enterprises.Foreign Tax authorities are responding in this Field of taxation with assessments, whether are Taxpayer’s Transfer Pricing arm’s lenght or not. If not, this probably means, that Transfer Pricing are abused for allocation of Profit in Low – tax countries. This has significant influence on reduction of public revenues and on increasing of such companies Profit.Tax authorities are responding on this situation by evaluating Transfer Prices with special Instrument. This Instrument are Transfer Pricing methods, such as: Comparable uncontrolled Price Method, Resale Price Method, Cost Plus Method, Profit split Method and Transactional net margin method. Global formulary apportionment Method was presented lately and did not get suitable answer in any legislation yet, because of restricting of each State sovereignty.Guidelines for appropriate settlement in each country are presented in Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, issued by OECD in 1995. This Guidelines need to be completed in each country separately because of market legislation and market particularise.Appropriate regulation of Transfer Pricing is important for Tax equalisation for all economic subjects in by that avoiding of Tax influences on economic concentration. Purpose of this research will be in appropriate settlement of Transfer Pricing legislation because of insufficiencies in present legislation. Special intention will be given to mentioned OECD Guidelines because of unsuitable characteristics of some Transfer Pricing Methods in New economy conditions.
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