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...

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 Research Paper commences with an overview of Pillar One and Pillar Two followed by detailed discussions on salient provisions of Pillar Two. Pillar Two is envisaged to have a widespread impact on Small Island Developing States (SIDS) which are a distinct group of 38 United Nations (UN)...

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...

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...

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...

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...

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...

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...

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...

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...

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...

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...

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...

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...

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...

We study the welfare and distribution effects of corporate taxation and transfer pricing in an asymmetric general oligopolistic equilibrium trade model. Without profit shifting, an increasing profit tax rate shifts welfare towards the taxing country, where it also decreases real wages, whereas...

We study the link between a country’s institutional quality in tax collection and its optimal corporate tax policies in a model of heterogeneous multinationals that can shift income using both debt and transfer prices. Countries with weak institutional quality can be made worse off adopting...

This study develops a model in which a multinational firm creates a brand that generates income in multiple countries. Many firms attempt to develop a brand, but only one firm succeeds. The firm that creates the brand earns positive residual profits. The industry as a whole does not, as the...

We study the relation between patent concentration and tax-motivated income shifting. Using affiliate-level data for European multinational corporations (MNCs) and employing the relative share of patents held by an MNC as a measure for patent concentration, we predict and find that tax-motivated...

This study creates and analyzes a model in which the income from intellectual property (IP) owned by a domestic parent and foreign subsidiary must be shared between the domestic and foreign countries for tax purposes. The model focuses on the effects of the commensurate with income standard,...

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...

In order to create complex business structures and to obtain economic benefits, multinational companies have given rise to transfer pricing. Due to their importance, it has been possible to expand international trade to a higher level. This study focuses on the issue of transfer pricing and...

In-kind transfers can provide insurance benefits when prices of consumption goods vary, as is common in developing countries. We develop a model demonstrating that in-kind transfers are welfare improving to beneficiaries relative to cash if the covariance between the marginal utility of income...

The OECD project against BEPS has brought and initiated many changes - among others, in the OECD Transfer Pricing Guidelines. To react and respond to changes in the current business environment, a new chapter for transfer pricing in financial transactions has also been introduced (namely chapter...