Part 1 - AL-Tax

136Table 6.2(Continued)Analytical Factor Definition and item Countries compared EffectleveldescriptionEconomic conditions and attractivenessEconomy Economic Share of cross-border Large share Large share Indifferentdemand for related-party businessAPAs (MNC business) to totalcross-border businessbetween two countriesIndustry Business Type of transaction and Industry type: Computer Ditto. Indifferenttype business to be covered and electronics Cf. IRS statistics No publiclyby the ex-ante APA manufacturing, (IRS, 1999–2005a) available(possible characteristics: aeronautics industry, statistic inLarge profit/loss volatility, pharmaceuticals, banking,Germanyhigh margins, high etc. available torelevance of intangibles Transaction type: Sales of compare withlike patents, trademarks, tangible and intangible, US statisticsetc.)services, use of intangible,financial loansEconomic Economic Degree of economic Post-industrialized Post-industrialized Indifferentenvironment stability and reliability economic environment; economic environment;(‘post-industrialized’ Relatively mature tax Relatively mature taxcountries versus code system code system‘transition’ countries)Governance Type of audit Purpose of audit in the Audit as an administrative Audit as an essential Yescourse of corporate step in the course of the administrative test to check