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...

Organisations these days are growing rapidly, and both operational activities and business networks tend to use business unit strategies to overcome operational complexity. This constantly growing environment can significantly impact multinational transfer pricing practices. The research aims to...

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 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...

This paper seeks to contribute to the current debate on EU-wide corporate taxation, steered by the impending Proposal by the European Commission on a new framework for the taxation of income of businesses in Europe. The objective of this paper is to verify whether the inclusion of intangible...

In this paper, we study another approach to the profit shifting costs function of multinational profit shifting. First, we describe the modelling approaches of such costs functions and provide a synthesized analysis. More precisely, we investigate the involved resource costs that multinational...

Purpose - For many global firms and corporate oligopolies, transfer pricing is essential. The transfer pricing literature as it is currently written is succinctly summarized in this study. The authors offer a thorough analysis of transfer pricing research in this study. This review sheds light...

This research examines the relationship between audit quality and transfer pricing aggressiveness (TPAG), the impact of TPAG on firm risk, and the indirect effect of audit quality on firm risk through TPAG. The research is important in reaffirming the auditor-client relationship, increasing...

Multinational profit shifting by mis-pricing of intra-firm trade is a major concern for less developed countries (LDCs). Many have enacted transfer pricing rules in order to constrain this type of tax avoidance behavior. Yet, not much is known on the rules' fiscal and economic effects. We offer...

Members of marketing airline alliance on one hand cooperatively booking seats from the operating airline, and on the other hand compete with each other in the market. Two types of bargaining process including representative based and agent based cooperative bargaining are respectively modeled...

This Note by Thomas C. Pearson was published in New York University Journal of International Law and Politics in 2008 (submitted in 2005). The Note foreshadowed the two pillars of the 2021 Global Agreement on Corporate Tax by the G20. The Note analyzed the abusive tax avoidance problem with the...

Profit shifting by multinational corporations is thought to reduce tax revenue around the world. While transfer pricing regulations are meant to curtail profit shifting, there have been rising concerns that a sophisticated tax advisory industry can limit their effectiveness. This paper provides...

Firms can purchase innovation results to improve their technology. In this context, the key to transfer success is reasonably priced innovation results. Considering the match between innovation results and firm technology, this study analyzes the nonlinear improvement effect of innovation...

This paper is devoted to an analysis of the recently promoted OECD/G20 reform and its potential effects on international taxation. Over the years, the efforts that the OECD and the European Commission had directed towards the development of an efficient international taxation system have been...

The greatest threat to a comprehensive tax regime in Africa is the tax planning strategy of multinationals operating within the continent, specifically the transfer pricing strategy of Multinationals. This strategy has been deployed by multinationals operating across the globe, and particularly...

The study considers transfer pricing in the system of formation of agro-product clusters. The system of transfer pricing in the formation of agro-product clusters for the development of the agro-food sphere actualized the model that accelerates the investment development of agricultural...

Profit shifting by multinational corporations is thought to reduce tax revenue around the world. While transfer pricing regulations are meant to curtail profit shifting, there have been rising concerns that a sophisticated tax advisory industry can limit their effectiveness. This paper provides...

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...

Transfer prices (TP) are charged for products or services exchanged between units within a decentralized organization. A vast body of literature from three very different academic disciplines (legal, management and economics) is concerned with the topic of Transfer Pricing. Their perspectives as...

Countries around the world have, over recent years, introduced transfer pricing regulations to constrain multinational profit shifting from high-tax to lower-tax affiliates through strategic mis-pricing of intra-firm trade. In this paper, we rely on rich administrative firm-level trade data for...