Transfer pricing charged by the French and Brazilian companies between 1994 and 2010 : ‘intangible property rights case'
type: Dataset
description: Transfer pricing are the prices to which services, the tangible property and intangibles are exchanged between parties with a link dependency in cross-border operations. The transfer pricing of the transactions with the intangible property rights adopted by a group of parties having a bond of dependence have a direct incidence on the benefit declared by each one as of these parts in their respective country. The French and Brazilian legislative measures incorporate the principle Řarms, however implicitly. The question of whether a taxpayer has respected the principle Řarms, however implicitly is a matter of fact to be examined in each case.
landing page: https://theses.hal.science/tel-00673607
identifier: NNT: 2010PEST2004
keyword: bien-incorporel
keyword: brazil
keyword: bresil
keyword: contribuable
keyword: france
keyword: infoeu-reposemanticsdoctoralthesis
keyword: intergroup
keyword: intragroupe
keyword: price
keyword: principe-de-pleine-concurrence-france-bresil
keyword: principle-arms-length
keyword: prix
keyword: property-intangible
keyword: shsdroithumanities-and-social-scienceslaw
keyword: taxpayer
keyword: theses
keyword: transaction
issued: 2026-05-27T05:05:57.952245
modified: 2026-05-27T05:05:57.952251
language: fr
contact point: Organization
  fn: CCSD

test_moissonnage_selune
type: Agent

Transfer pricing charged by the French and Brazilian companies between 1994 and 2010 : ‘intangible property rights case'
type: Distribution
format: HTML
access URL: https://theses.hal.science/tel-00673607
issued: 2026-05-27T05:05:57.988642
modified: 2026-05-27T05:05:57.915482