Transfer pricing (TP) is based on many principles - the essential one is the Arm ́s Length Principle (ALP), In this respect, the term "associated persons" is of crucial importance: associated persons must be involved in transactions in order for the ALP to be applied, The aim of the paper is to...

The study evaluates the direct and moderating influence of Country-by-Country Reporting (CbCR) regulation in deterring corporate tax avoidance of multinational corporation listed in Indonesia Stock Exchange. The Indonesian CbCR stated in the regulations enacted by government of Indonesia namely...

This paper reconsiders the empirical evidence of the relationship between tax treaties and FDI using U.S. outbound FDI to 78 countries over the period of 2007-2018. Unlike previous studies, we explicitly consider differences in the tax environments of recipient economies, including their...

The main objective of this work is to assess the challenges to be faced by Brazil to become a full member of the Organisation for Economic Co-operation and Development (OECD) in terms of tax rules related to controlled foreign companies, transfer pricing, thin capitalization, and mandatory...

Geschäfte mit Nahestehenden: Eine grundsätzliche Lösung für das Außensteuer-, Handels- und Gesellschaftsrecht - Unter besonderer Berücksichtigung von BEPS Bericht 8 und des Wettbewerbsrechts Gliederung 1. Einleitung 2. Wesentliche Ergebnisse der Untersuchung 3. Zusammenfassung 1....

Kürzlich hat die Verfasserin ihre Dissertation mit dem Titel „Geschäfte mit Nahestehenden: Eine grundsätzliche Lösung für das Außensteuer-, Handels- und Gesellschaftsrecht - Unter besonderer Berücksichtigung von BEPS Bericht 8 und des Wettbewerbsrechts“ veröffentlicht. Aufgrund der...

This paper reflects the tabled novel framework for corporate taxation in the European Union, founded on the Formulary Apportionment methodology and envisaged inclusion of intangible assets in the allocation formula. The objective is to simulate the variation between the currently used Separate...

The purpose of the study is to analyze the practice of involving multinational companies in achieving the Sustainable Development Goals (SDGs), in general, and the response to SDG 16 "Peace, Justice and Strong Institutions". The research methodology involves a comparative analysis of the...

Many federal tax systems employ formula apportionment to allocate the taxable profits of large businesses to the federal subunits, where the subunits' specific tax rates are then applied. The formulas - such as the one recently proposed by the EU Commission and the one agreed upon by the...

The main objective of this work is to assess the challenges to be faced by Brazil to become a full member of the Organisation for Economic Co-operation and Development (OECD) in terms of tax rules related to controlled foreign companies, transfer pricing, thin capitalization, and mandatory...

We study the choice between source-based and destination-based corporate taxes in a two-country model, allowing multinational firms to use transfer pricing to allocate profits across tax jurisdictions. We show that source-based taxation is a Nash equilibrium for tax revenue maximizing...

This study investigates how strategic tax transfer pricing of a multinational company (MNC) and two tax authorities in different countries affects production and tax avoidance decisions at the firm level and tax revenues at the country level. We employ a game-theoretical model to analyze the...

This study investigates how strategic tax transfer pricing of a multinational company (MNC) and two tax authorities in different countries affects production and tax avoidance decisions at the firm level and tax revenues at the country level. We employ a game-theoretical model to analyze the...

Zambia has changed its mineral tax regime repeatedly during the past decades in a bid to raise mineral revenue, but with only modest success. This paper looks at what the country needs to do to create a mining fiscal regime that could sustain operations, boost output, and raise revenues without...

We study the relative efficiency of centralized versus decentralized organizational forms given optimized managerial performance evaluation within an incomplete contracting framework with risk‐averse agents under moral hazard. Decentralization and performance evaluation are complementary...

The study evaluates the direct and moderating influence of Country-by-Country Reporting (CbCR) regulation in deterring corporate tax avoidance of multinational corporation listed in Indonesia Stock Exchange. The Indonesian CbCR stated in the regulations enacted by government of Indonesia namely...

We examine distortions caused by tax base allocation systems–separate accounting (SA) or formula apportionment (FA)–with respect to the allocation of assets and workforce within multinational entities (MNEs). The effects of both systems are intensively debated by EU Member States as they are...

The quest to ensure that the tax planning activities (e.g., shifting profits through transfer mispricing) of multinational enterprises operating in Nigeria do not erode the country’s domestic base has led to the enactment and enforcement of the Transfer Pricing (TP) Regulation, 2018 in...

Much international technical assistance is directed towards increasing the capacity of tax authorities in low-income countries to understand and effectively implement the OECD Transfer Pricing Guidelines, and thus retain their fair share of revenue from the transnational economic transactions of...

This paper analyzes the transfer pricing decision of the multinational firm (MNF). There are differences in profit tax rates between home-country and host-country. The MNF determines the transfer price to its overseas affiliate and delegates the responsibility of deciding on the final sales...

The overwhelming complexity of transfer pricing within income taxation and the number of available materials generates significant entry barriers for conducting adequate research in this field. The objective of this contribution is to briefly depict the most relevant issues and provide basic...

The current lack of confidence in the international rules for taxing the global profits of multinational enterprises (MNEs) has three underlying causes: (1) tax rules are not universal or natural; (2) taxes must be practical, administrable, and collectible; and (3) tax policy is a domain where...

In recent years, a growing number of countries have enacted tax rules that require multinational enterprises (MNEs) to document their intra-firm trade prices and show that they are set as in third-party trade. The objective of these rules is to limit opportunities for strategic trade mis-pricing...

In recent years, a growing number of countries have enacted tax rules that require multinational enterprises (MNEs) to document their intra-firm trade prices and show that they are set as in third-party trade. The objective of these rules is to limit opportunities for strategic trade mis-pricing...

The 2015 OECD review of its transfer pricing guidance was in part focussed on the need to align transfer pricing outcomes with value creation, a process that was based on open market benchmarking and an examination of the economic functions performed, assets used and risks assumed by the...