This paper aims at providing a comprehensive overview of existing literature on the topic of comparability adjustments. Based on existing literature the most commonly used adjustments can be categorized in two broad categories: “accounting and financial risks adjustments” and...

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...

The World Customs Organization (WCO) and the Organization of Economic Cooperation and Development (OECD) have begun considering the harmonization of transfer pricing norms among income tax, customs and VAT regimes. Two conferences have been organized in May of 2006 and 2007. These conferences...

The goals of transfer pricing are to assign a monetary value to a transfer and to minimize the taxes paid by a company as whole. However, because a single company can now have operations literally around the world, transfer pricing has become a very complicated, costly, and lucrative business...

Transfer pricing taxation is a significant source of tension between Multinational Firms (MNFs) and tax authorities. The tension relates to the different perspectives of MNFs and tax authorities. MNFs view taxes related to transfer prices as costs to avoid. On the other hand, regulators and tax...

The Global Formulary Apportionment Model (GFA Model) applies to the tax accounting of the Global Taxable Income (GTI) of a Multinational Enterprise (MNE) and the Formulary Apportionment (FA) of this GTI between the member states of the model – here the G 20 nations. The resulting Global...

A key motivation underlying the October 2020 OECD Pillar One and Pillar Two Blueprints is the goal of reducing tax complexity for taxpayers and tax authorities. In this article, we assess the tax complexity of the Blueprints relative to the 2017 OECD Transfer Pricing Guidelines (TPG) and the...

Most papers on transfer pricing deal either with technical aspects of the topic or strategy. Research on ethical aspects of transfer pricing is almost totally absent from the business literature and is scantly covered in the ethics literature. The purpose of this paper is to fill that gap....

When a Canadian parent corporation guarantees a debt obligation incurred by its foreign affiliate subsidiary, the issue arises whether the Canadian transfer pricing rules require the Canadian parent to receive an arm's length guarantee fee from the foreign affiliate. Proposed subsection 247(7.1)...