英语翻译Today‘sinternationaltax-worldoftransferpricingandincomeallocationreliesonanarrowALPconcept.Giventhegovernancedifferencebetweenfirmsandmarkets(Coase,1937;Williamson,1975),itneglectsfundamentalinsightsfromtheth

Question

英语翻译
Today‘s international tax-world of transfer pricing and income allocation relies on a narrow ALPconcept.Given the governance difference between firms and markets (Coase,1937; Williamson,1975),it neglects fundamental insights from the theory of organization and governance.11 As aresult,external transactions between independent parties and organization-internal transactionsbetween dependent parties (related parties) are not distinguished from each other with respect togovernance differentials.A simplified ALP approach lacks the power to grade organization-internal transactions in accordance with the incurring governance features such as coordination,incentive,and safeguards.If the objectives are,however,that the transfer prices are supposed toproperly address the incentives needs,the coordination,the control issues,and the incomeallocation,such grading becomes highly relevant.
This paper seeks to contribute to the discussion on how the next-generation of transfer pricingcould look like.The core of the paper is on the problem of identifying entrepreneurial activitywithin the (multinational) organization with respect to coordination efforts subject to theinstitutional environment,the governance structure,and the dynamics of the firm.In other words,we consider —coordination“ and —governance“ of transactions as key features of value processes inan organization.
2 “Mainstream“ Transfer Pricing:Some Remarks
Art.9 of the OECD Model Tax Convention12 provides the basic principle,the so-called Arm´sLength Principle (ALP),shaping tax transfer pricing.Art.9 Section 1 reads as follows:
Where
a) an enterprise of a Contracting State participates directly or indirectly in themanagement,control or capital of an enterprise of the other Contracting State,or
b) the same persons participate directly or indirectly in the management,control orcapital of an enterprise of a Contracting State and an enterprise of the otherContracting State,
and in either case conditions are made or imposed between the two enterprises in theircommercial or financial relations which differ from those which would be made betweenindependent enterprises,then any profits which would,but for those conditions,haveaccrued to one of the enterprises,but,by reason of those conditions,have not so accrued,may be included in the profits of that enterprise and taxed accordingly.

Answer 1

今天的国际tax-world和收入分配的转让定价ALPconcept依赖于一种狭窄.给企业和市场治理区别(科斯,1937年,威廉姆森,1975年),它忽视基本的洞察力的理论来组织和governance.11作为终局,独立的外部交易当事人和organizati...