Aggressive tax planning efforts of highly profitable multinational companies (Base Erosion and Profit Shifting (BEPS)) have become the subject of intense public debate in recent years. As a response, several international initiatives and parties have called for more transparency in financial...

The taxation of the mining industry varies considerably from nation to nation. This paper reflects on the evolving use of various taxation approaches applied by governments to the mining sector. It includes a description of the principal tax types and investment tax incentives and briefly...

This paper employs unique data on export transactions and corporate tax returns of UK multinational firms and finds that firms manipulate their transfer prices to shift profits to lowertaxed destinations. It uncovers three new findings on tax-motivated transfer mispricing in real goods. First,...

Small and medium sized enterprises account for over 99% of all companies in Eu-ropean Union and have very important position in the EU economy in the area of growth and employment. However, they face great deal of obstacles, such as com-pliance costs of taxation, 28 different tax systems in...

Purpose- This paper aims to discuss the challenges of the switch from the US GAAP into International financial Reporting Standards (IFRS) pose multinational companies (MNCs); to investigate the transfer pricing of intangible assets with several important trends in the global market; to analyze...

Based on a natural experiment that took place in Ecuador in the context of a capital outflow tax, this paper presents suggestive evidence of the emergence of an abnormal transfer pricing behavior. We exploit the fact that some imports were eligible to a tax-credit measure aiming to offset the...

According to the dealing at arm’s length principle, the price of goods transferred or services within MNE groups should be determined by the market forces. The requirement for this, is that the market prices for such goods or services are known or can be determined. However, market prices are...

Related party transactions and transfer prices have begun to be considered a powerful instrument of financial frauds as a result of the recent financial scandals. Transactions with related parties situated in tax havens are one of the principal elements which contribute to the faltering...

This paper analyses the characteristics of transfer pricing systems across countries, in order to identify the grouping structures intrinsically related with rules' similarities, and to explore the key characteristics revealed by each group. Applying hierarchical agglomerative technique for...

With opening of the economy in 1991 and subsequent removal of regulatory and trade barriers, India became an attractive investment (Foreign Direct Investment-FDI) destination. A large number of multinationals have established operations in India to utilise the services of available skilled...

In diesem Beitrag wird die theoretische Basis und der Stand der empirischen Forschung des Kontingenzansatzes des Behavioral Accounting zur Gestaltung unternehmensinterner Abrechnungssysteme ausgewertet. Als wichtigstes Ergebnis bleibt festzuhalten, daß über die Auswahl bestimmter...

This article presents a case for transfer mispricing as an argument for Corporate Social Responsibility (CSR). The argument builds on the position that in order to compensate for potential loss of brand image and reputation, Multinational Companies (MNCs) would be more socially responsible when...

A recent publication by the World Bank on Millennium Development Goals (MDGs) has established that extreme poverty has been decreasing in all regions of the world with the exception of sub-Saharan Africa (SSA), in spite of over two decades of growth resurgence. This chapter explores the role of...

A recent publication by the World Bank on Millennium Development Goals (MDGs) has established that extreme poverty has been decreasing in all regions of the world with the exception of sub-Saharan Africa (SSA), in spite of over two decades of growth resurgence. This chapter explores the role of...

The predominant model of tax induced transfer pricing is based on the assumption that profit shifting is due to insufficient enforcement. However, evidence shows that the firms responsible for most profit shifting are also among the most frequently audited. We present an alternative model based...

This paper analyzes the optimal level of transfer pricing manipulation when the expected tax penalty is a function of the tax enforcement and the market price parameter, and the multinational enterprise is subjected to distinct rules of foreign profit taxation. The application of the arm's...

In December 2014, OECD issued a Discussion Draft on Transfer Pricing aspects of cross-border commodity transactions through BEPS action 10, where the adoption of the sixth method in the form of the quoted commodity price and its adjustments were primarily driven as a starting point for transfer...

The adequate pricing of intellectual property ("IP") for tax reporting is a largely unsettled issue. Transactional profit-based methods are on the rise although only rated as "methods of last resort" by the OECD. This paper focuses on regulated profit splitting and compares this transfer pricing...

This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle...