In this paper we theoretically analyse the European Union's ongoing political impasse regarding the choice of a single method to allocate multinational enterprises' profits across countries and we find that this strategic situation resembles a coordination game with distributional consequences....

To combat firms exploiting transfer pricing as a tool for tax avoidance, the Organisation for Economic Co-operation and Development (OECD) introduced the Base Erosion and Profit Shifting Action 13 (BEPS 13), enhancing tax transparency and the exchange of information with tax authorities....

We study how the OECD transfer pricing guidelines aimed at curbing tax-motivated transfer pricing practices affect investment incentives. Our theoretical model integrates the different OECD's transfer pricing methods into the tax planning cost function of an MNC to evaluate how the choice of...

This study provides empirical evidence of tax-induced profit-shifting by multinational corporations (MNCs) operating in Morocco, an underexplored developing country context characterized by notable tax arbitrage potential. Using a micro-level panel dataset of foreign-owned subsidiaries from 2014...

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...

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 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...

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...

Geschädigte von Verstößen gegen deutsches und europäisches Kartellrecht haben einen Anspruch auf den Ersatz des ihnen entstandenen Schadens (§ 33a GWB). In der Praxis gibt es oft einen Dissens zwischen Klägern und Beklagten darüber, wie hoch der entstandene Schaden tat sächlich ist. Zur...

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...

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...

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...

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...

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...

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 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...

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...

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...

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...

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...

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...

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...

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...