Relevant bibliographies by topics / Transfer pricing

Academic literature on the topic 'Transfer pricing'

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Published: 4 June 2021
Last updated: 30 July 2024

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Journal articles on the topic "Transfer pricing"

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Saputra, Gani. "Pengaruh Pajak, Ukuran Perusahaan, Profitabilitas Terhadap Transfer Pricing Dengan Leverage Sebagai Variabel Moderasi (Stusi Empiris Perusahaan Manufaktur Sektor Makanan dan Minuman Tahun 2017-2021)." Jurnal Literasi Akuntansi 3, no. 1 (March 29, 2023): 10–21. http://dx.doi.org/10.55587/jla.v3i1.88.

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Purpose: This study aims to show the effect of tax, company size and profitability on transfer pricing with leverage as a moderating variable. The nature of this research is quantitative. Methot: The population in this study are food and beverage sub-sector manufacturing companies listed on the Indonesia Stock Exchange in 2017-2021 and there are 40 companies. The research sample used purposive sampling and obtained 15 companies. This research uses secondary data in the form of financial reports and company annual financial reports which are downloaded from www.idx.co.id and the website of each company that is the sample in this study. Data analysis using multiple linear analysis and moderate regression analysis. Finding: The results of this study indicate that taxes have a positive effect on transfer pricing. Company size has a positive effect on transfer pricing. Profitability has a positive effect on transfer pricing. Leverage can strengthen the positive effect of taxes on pricin transfers. Leverage can strengthen the positive influence of company size on transfer pricing. However, leverage cannot moderate the effect of profitability on transfer pricing.
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Nerudová, D., and V. Solilová. "Transfer pricing in agricultural enterprises." Agricultural Economics (Zemědělská ekonomika) 57, No. 7 (August 1, 2011): 311–21. http://dx.doi.org/10.17221/84/2010-agricecon.

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International tax issues already have not been problems of multinational enterprises. The effect of globalization and international business development causes that many small and medium size firms including agricultural entities are now engaged in the cross-border transactions and have to face the international tax issues. One of the important areas of international taxes is transfer pricing. The transactions between these persons should be assessed at their arm's length price according to the arm's length principle (internationally accepted standard) as the price which would have been agreed between the unrelated parties in free market conditions. The aim of the paper is to evaluate the impact of the selection of the form of the subsidiary on the total tax liability of the agricultural entity, including the determination of the transfer price, the application of the arm's length principle and decisions about the most suitable legal form of the subsidiary.
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Melnychenko, Ruslan, Kateryna Pugachevska, and Kyrylo Kasianok. "Tax control of transfer pricing." Investment Management and Financial Innovations 14, no. 4 (December 9, 2017): 40–49. http://dx.doi.org/10.21511/imfi.14(4).2017.05.

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The subject of the scientific work is analysis of the essence of the “transfer pricing” concept. It has been proven that transfer pricing is an economic and legal tool used by business entities for their tax burden optimization. It has been concluded that the concept “transfer price” means the price generated by multinational corporations in the process of commercial activity between the affiliated companies located in different countries and, correspondingly, different tax jurisdictions. In essence, transfer pricing means intra-company pricing of goods transferred between the enterprise subdivisions located in different countries. Base erosion by means of transfer pricing can be performed not only based on the price manipulating by the affiliated companies, but also as a result of manipulating incomes and expenditures. The latter is accompanied by the financial resource withdrawal outside the national economy and its concentration in the low taxation jurisdictions. Transfer pricing bears serious risks both for an individual country and for the world economy. Contractual freedom of transnational corporations and industrial and financial groups cannot be unlimited regardless of the principle of freedom of contracts in the private law relations. Economic activity of such business entities must subject to a strict control on the part of the country. In the process of transfer pricing tax control, the controlling state agencies are intended to prevent the decrease of tax liabilities by shifting the income to low tax jurisdictions by taxpayers.
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Muzychuk, Mariana I. "Risk Assessment Methods of Transfer Pricing." Business Inform 8, no. 547 (2023): 254–63. http://dx.doi.org/10.32983/2222-4459-2023-8-254-263.

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Transfer pricing is one on the greatest problem of the global system of taxation and therefore the efficient TP tax control is of special importance. As the risk-oriented approach allows to improve the TP tax control, tax administrations as well as businesses should apply and develop it for the timely risks identification. This assumption is based on the review of foreign and domestic scientific literature provided in this article. This study aims to analyze the significance of TP risk management system and its impact on the TP tax control and voluntary tax compliance as well as to develop proposals on the TP risks assessment methods, focusing on Ukrainian tax regulation as well as the OECD and the EU tax framework. The research methods include systematic and comparative analysis of scientific literature, deduction, induction, analysis, synthesis and systems approach. To fulfill the objective of this study the analyses of legislative regulation of the TP control at both the international and the country level is provided, focusing on the stage of the monitoring of the controlled transactions. For the enhancement monitoring stage of the TP control the algorithm for the risk identification and assessment for the monitoring of controlled transaction (CT) is suggested. The study also provides for the methodology on comparison of the profitability of taxpayers with the average in the industry and methodology for building the TP risks matrix. The study results revealed the significance of the TP risks management processes standardization that allows its automatization and could contribute to the TP tax control strengthening as well as an TP compliance improvement. The prospects for future research could be focused on development of an algorithm for comparing the prices of CT with the quoted prices for raw materials.
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Bokšová, Jiřina. "Transfer Pricing." Český finanční a účetní časopis 2007, no. 2 (June 1, 2007): 28–33. http://dx.doi.org/10.18267/j.cfuc.219.

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Majmudar, Jalpa. "Transfer Pricing." Ushus - Journal of Business Management 3, no. 1 (June 10, 2006): 66–75. http://dx.doi.org/10.12725/ujbm.4.8.

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Finance Act, 2001 has defined a hitherto ill-defined section/piece(?) of IT Act, 1961, ie., Transfer Pricing. This has enabled the tax laws dealing with International Transactions to effectively deal with the same.
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Caraccioli, Ivo. "Transfer Pricing Audits: Suitability of Transfer Pricing Documentation." Intertax 45, Issue 6/7 (June 1, 2017): 501–6. http://dx.doi.org/10.54648/taxi2017042.

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Article 26 of Legislative Decree No. 78/2010 introduced in Italy a rewarding regime related to the non-application of penalties involving intercompany transfer pricing adjustments in connection with taxpayer’s submission to the Tax Authorities of ‘suitable’ documentation to support taxpayer’s transfer pricing policies. Assessment on the ‘suitability’ of such documentation by Tax Inspectors has given rise to a variety of critical issues in the last few years.
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Holtzman, Yair, and Paul Nagel. "An introduction to transfer pricing." Journal of Management Development 33, no. 1 (February 4, 2014): 57–61. http://dx.doi.org/10.1108/jmd-11-2013-0139.

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Purpose – The purpose of this paper is to introduce transfer pricing to a broader community of business leaders who might not be familiar with the importance of this concept. Transfer pricing is a term used to describe inter-company pricing arrangements relating to transactions between related business entities. These can include transfers of intellectual property, tangible goods, services, and loans or other financing transactions. Why is Transfer Pricing Important? The potential for US federal business tax reform and the rigorous pursuit of transfer pricing adjustments by foreign countries are among the top global tax concerns facing senior US tax professionals. Design/methodology/approach – General viewpoint based upon years of consulting work on the topic. Findings – The relevance and importance of transfer pricing is emphasized to a larger business community. Practical implications – This is an excellent introduction to the topic of transfer pricing. Originality/value – The paper is valuable in that it can be read and appreciated by a wide range of audiences.
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Chan, K. Hung, Agnes W. Y. Lo, and Phyllis Lai Lan Mo. "Managerial Autonomy and Tax Compliance: An Empirical Study on International Transfer Pricing." Journal of the American Taxation Association 28, no. 2 (September 1, 2006): 1–22. http://dx.doi.org/10.2308/jata.2006.28.2.1.

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This paper examines the impact of managerial autonomy on tax compliance in an international transfer pricing context. Specifically, we study whether foreign subsidiaries' autonomy in making pricing and sourcing decisions on intrafirm transfers affect their profit shifting through international transfer pricing. We measure transfer pricing noncompliance in terms of tax audit adjustments made by tax authorities. Based on a sample of 163 transfer pricing audits on foreign investment enterprises (FIEs) in China, we find that tax audit adjustments for FIEs that have autonomy in setting transfer prices or sourcing from outsiders are smaller than those that have their transfer transactions dictated by parent companies.
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Clarabella, Angelina, and Edi Pranoto. "JURIDICIAL ANALYSIS OF TRANSFER PRICING DOCUMENTS IN RESPECT OF TAX AVOIDANCE FOR MULTINATIONAL COMPANIES." UNTAG Law Review 5, no. 2 (December 11, 2021): 49. http://dx.doi.org/10.56444/ulrev.v5i2.2657.

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<span class="fontstyle0">Essential principle within business world definitely would be maximizing profit and minimizing capital. Hence many companies would struggle<br />and develop their own ways to avoid taxes as much as they could. Tax avoidance which is taken illegally would disrupt government's revenue indeed. This paper discusses normative juridical approach to examine problems as 1. How does transfer pricing documents could help to diagnose tax avoidance practice within companies? 2. How to prevent the occurrence of transfer pricing's shortcomings? This would highlight the transfer pricing's existence to eliminate illegal practice of tax avoidance<br />within multinational companies and some methods to prevent the shortcomings of transfer pricing. The results shows that 1. transfer Pricing documents are useful for diagnosing tax avoidance practices in multinational companies through an analysis of fairness and business practice and 2. in order to prevent deficiencies in Transfer Pricing documents, the Government must establish a cooperative relationship<br />between companies and reliable tax administrations. such as through AEoI (Automatic Exchange of Information) between countries to encourage transfer pricing inspection processes in multinational companies. The government should conduct cooperative relationship between the companies and tax administration to encourage the process of transfer pricing examination within multinational companies in precise scheduled time frame. Fair and favorable assessment of business report is significant due to undermine unnecessary cost and improper result.<br />The competence and professional judgement from the Directorate General of Taxes are substantial.</span> <br /><br />
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Dissertations / Theses on the topic "Transfer pricing"

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Gesua', Sive Salvadori Davide <1993&gt. "Transfer pricing." Master's Degree Thesis, Università Ca' Foscari Venezia, 2017. http://hdl.handle.net/10579/10654.

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Möllerstedt, Lena. "Transfer Pricing : Svenska domstolars tillämpning av OECD Transfer Pricing Guidelines vid armlängdsprisberäkningar." Thesis, Jönköping University, JIBS, Commercial Law, 2005. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-359.

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Ren, Linghui, and 任凌晖. "Transfer pricing in China." Thesis, The University of Hong Kong (Pokfulam, Hong Kong), 2010. http://hub.hku.hk/bib/B45157819.

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Tisa, Pornprapa. "The Transfer Pricing Act of Thailand : Critical Comparison with the OECD Transfer Pricing Guideline." Thesis, Uppsala universitet, Juridiska institutionen, 2019. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-384504.

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Lindman, Carl-Johan. "Tax Penalties in Transfer Pricing." Thesis, Uppsala universitet, Juridiska institutionen, 2019. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-389627.

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The purpose of this thesis is to examine both the conditions for levying tax penalties in transfer pricing and the sustainability of the Swedish tax penalty framework in regard to transfer pricing in a post-BEPS world. This question is of relevance as BEPS has resulted in more extensive documentation requirements, affecting both the tax payer’s tax assessment procedure and the Swedish Tax Agency’s auditing practice. Tax penalties were introduced in order to incentivize the tax payer to disclose relevant information for the tax assessment. The scope of relevant information is relative to the correction rule, which has a significant connection to the OECD and BEPS. This thesis concludes that in a post-BEPS world, relevant information relates to domestic developments of the correction rule produced by the legislator, case law and the Swedish Tax Agency. Furthermore, this thesis concludes that transfer pricing documentation in full compliance with the Swedish content requirements should greatly mitigate a tax payer’s risk of being subjected to tax penalties. Court rulings from the lower administrative courts regarding tax penalties in transfer pricing demonstrate contradictory views to that of statutory law, case law and preparatory works. These opposing views constitute the current framework of tax penalties in transfer pricing, which is neither sustainable nor appropriate. For this reason, the Swedish tax system requires either extensive case law or statutory reform on the subject. This thesis concludes that statutory reform would perhaps be the most appropriate development in light of certain aspects of the principle of legality. Proceeding from that conclusion, this thesis therefore presents two amendments to the Swedish tax penalty framework in regard to transfer pricing.
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Catalani, Matteo <1993&gt. "Transfer Pricing in multinational groups." Master's Degree Thesis, Università Ca' Foscari Venezia, 2019. http://hdl.handle.net/10579/15814.

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L'elaborato si pone l'obiettivo di approfondire il tema dei transfer pricing all'interno dei gruppi multinazionali. Partendo dall'ambito di applicazione dei prezzi di trasferimento, fino ad arrivare ai metodi di determinazione dei prezzi stessi.
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Wu, Ronald. "Transfer Pricing: Current Problems and Solutions." Scholarship @ Claremont, 2010. http://scholarship.claremont.edu/cmc_theses/87.

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The current problems and possible solutions surrounding United States transfer pricing regulations are discussed and studied. The schemes large multinational companies are implementing to legally evade taxes are uncovered as the financial effects to the United States Treasury and government are becoming material. The benefits for these schemes are financially advantageous for corporations as they are able to report larger profits and higher returns for investors. But this is being done at the expense of our government. Corporations are finding ways to escape the high U.S. corporate tax rate and lower their global tax liabilities by allocating income to lower tax jurisdictions. Tax havens like Ireland or Bermuda are popular to have subsidiaries which hold a corporations intangible property. Five United States Tax Court cases concerning transfer pricing are studied and the outcomes are analyzed. The current problems studied from these cases are, shipping intangible property, valuing intangible property, the arm’s length standard. The possible solutions to these currents problems are by no means easy to solve and no one revision can relieve all the problems. The arm’s length standard is the corner stone to the current problems and if the government can find a way to better enforce the standard or replace it, it will be a large step in the right direction.
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Abu-Serdaneh, Jamal Abdel-Rahman. "Transfer pricing in UK manufacturing companies." Thesis, University of Huddersfield, 2004. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.405183.

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Quan, Lianfeng. "Funds transfer pricing and performance evaluation." Thesis, Bangor University, 2009. https://research.bangor.ac.uk/portal/en/theses/funds-transfer-pricing-and-performance-evaluation(dffbe8e5-21f4-4179-b123-b86f4b2fa3b6).html.

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Funds transfer pricing (FTP) is a management accounting technique used to identify the source of profits contributions for business units and products, and is a strategic tool to integrate risk management with decision-making. As very few studies have investigated the FTP model for commercial banks, this thesis attempts to identify the factors driving the bank FTP model and to develop the model. To develop the bank FTP model, the bank FTP process, which consists of the WHY, the WHAT, the WHO, the WHERE, the WHEN and the HOW factors, is designed. The WHY factor determines that the FTP model should be developed to enhance effective bank risk management process, and properly assign profit contributions within a bank to help achieve accurate bank performance evaluation. The WHERE factor demands that the FTP model should be developed at the bank business unit and instrument levels, and the WHEN factor requires that both the original and remaining term FTP models should be developed. The FTP model is developed with the responsibility accounting principles and financial risk management techniques, which are applied for the WHO, the WHAT and HOW factor design. The implications of the FTP model developed in this thesis are examined by applying the model in bank performance measurements. The FTP model is found to be able to properly assign bank risks to business unit managers who have control over the risks, and properly allocate profit contributions within a bank. The FTP model is also applied in the different types of banks, which have varying degrees of decentralization of risk management decision-making authority. It is found that the FTP model can achieves effective risk management and accurate business performance evaluation in the partially decentralized bank. The case study analysis of the FTP model in the Chinese bank shows that the bank FTP model developed in this thesis is more effective in risk management than the bank's FTP method.
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Kanee, Emmanuel Lah. "Strategies to Manage Transfer Pricing Risks." ScholarWorks, 2019. https://scholarworks.waldenu.edu/dissertations/7812.

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Transfer pricing compliance related issues continue to pose challenges to leaders of multinational entities (MNEs) and tax regulators. MNE leaders strive to mitigate the risks of non-compliance violations and double taxation, while tax regulators seek to minimize profit shifting and revenue losses. This multiple case study explored strategies for managing transfer pricing risks against the backdrop of various risks MNE leaders face for non-compliance violations. The cost contribution agreement theory served as the conceptual framework for this study. Data were collected from organizational documents and semistructured interviews conducted with 6 finance executives representing 2 multinational entities in the midwest and southwest regions of the United States who have implemented successful strategies to manage transfer pricing risks. Data were analyzed using Yin's multiple-step thematic analysis process. Following the thematic data analysis 5 themes emerged, including commitment to tax compliance, tax minimization, advance pricing agreement (APA), comparable uncontrolled price method (CUP), and cost plus method (CPM). MNE leaders favor commitment to tax compliance as an effective strategy as penalties for non-compliance increases risks to business functionality. The findings of this study may help business leaders to follow compliance procedures and adopt risk mitigation strategies, while also informing regulators to update tax regulations to reflect current economic realities. The findings of this study could result in positive social change through an enhanced governmental revenue that stimulates economic growth, improves productivity, and promotes technological innovations.
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Books on the topic "Transfer pricing"

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United Nations Conference on Trade and Development., ed. Transfer pricing. New York: United Nations, 1999.

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Stitt, Iain P. A. Transfer pricing. (London) ((1 Surrey St., WC2R 2PS)): Arthur Andersen & Co., 1988.

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Kamphuis, H. J. Transfer pricing. Deventer: Kluwer, 2011.

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Culbertson, Robert E. Transfer pricing: OECD transfer pricing rules and guidelines. [Washington, D.C.]: Tax Management Inc., 2005.

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Feinschreiber, Robert, and Margaret Kent, eds. Transfer Pricing Handbook. Hoboken, NJ, USA: John Wiley & Sons, Inc., 2012. http://dx.doi.org/10.1002/9781119203650.

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Lowell, Cym H. Transfer pricing strategies. Valhalla, NY: WG & L, Thomson Reuters, 2010.

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Robert, Feinschreiber, ed. Transfer pricing handbook. 3rd ed. New York: J. Wiley & Sons, 2001.

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Lowell, Cym H. Transfer pricing strategies. Valhalla, NY: WG & L, Thomson Reuters, 2010.

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Lowell, Cym H. Transfer pricing strategies. Valhalla, NY: WG & L, Thomson Reuters, 2010.

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Robert, Feinschreiber, ed. Transfer pricing handbook. 2nd ed. New York: J. Wiley, 1998.

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Book chapters on the topic "Transfer pricing"

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Salas-Fumas, Vicente, and Francisco Ruiz-Aliseda. "Transfer Pricing." In Operations Research/Computer Science Interfaces Series, 25–41. Boston, MA: Springer US, 2002. http://dx.doi.org/10.1007/978-1-4615-0893-9_3.

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Levy, Leon S. "Transfer Pricing." In Taming the Tiger, 199–219. New York, NY: Springer New York, 1987. http://dx.doi.org/10.1007/978-1-4612-4718-0_9.

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Nuggehalli, Nigam. "Transfer Pricing." In International Taxation, 75–82. New Delhi: Springer India, 2019. http://dx.doi.org/10.1007/978-81-322-3670-2_7.

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Lall, Sanjaya. "Transfer Pricing." In The New Palgrave Dictionary of Economics, 1–3. London: Palgrave Macmillan UK, 1987. http://dx.doi.org/10.1057/978-1-349-95121-5_1810-1.

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Mintz, Jack M. "Transfer Pricing." In The New Palgrave Dictionary of Economics, 1–4. London: Palgrave Macmillan UK, 2008. http://dx.doi.org/10.1057/978-1-349-95121-5_1810-2.

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Mintz, Jack M. "Transfer Pricing." In The New Palgrave Dictionary of Economics, 13801–4. London: Palgrave Macmillan UK, 2018. http://dx.doi.org/10.1057/978-1-349-95189-5_1810.

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Moosa, Imad A. "Transfer Pricing." In Foreign Direct Investment, 221–42. London: Palgrave Macmillan UK, 2002. http://dx.doi.org/10.1057/9781403907493_8.

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Lasiński-Sulecki, Krzysztof. "Transfer pricing." In Fair taxes or budget revenues at any price?, 135–52. Wien: Böhlau Verlag, 2022. http://dx.doi.org/10.7767/9783205215295.135.

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Wiederhold, Gio. "Transfer Pricing and Rights Transfers." In Management for Professionals, 63–84. New York, NY: Springer New York, 2013. http://dx.doi.org/10.1007/978-1-4614-6611-6_4.

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Li, Jian, and Alan Paisey. "Transfer Pricing Methods." In Transfer Pricing in China, 39–46. Singapore: Springer Singapore, 2019. http://dx.doi.org/10.1007/978-981-13-7689-4_5.

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Conference papers on the topic "Transfer pricing"

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Shuvalova, Elena. "THE SYSTEM OF TRANSFER PRICING." In 2nd International Multidisciplinary Scientific Conference on Social Sciences and Arts SGEM2015. Stef92 Technology, 2015. http://dx.doi.org/10.5593/sgemsocial2015/b22/s6.066.

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MAXIM, Ramona, and Florentina MOISESCU. "Transfer Pricing An Innovative Approach." In 18th edition of the Conference “Risk in Contemporary Economy” RCE2017, June 9-10, 2017, Galati, Romania. LUMEN Publishing House, 2017. http://dx.doi.org/10.18662/lumproc.rce2017.1.36.

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Simamora, Beatrice Eka Putri P., and Ancella Anitawati Hermawan. "Transfer Pricing Analysis on Intra-Group Services and the Related Transfer Pricing Disputes from Indonesian Tax Perspectives." In 6th International Accounting Conference (IAC 2017). Paris, France: Atlantis Press, 2018. http://dx.doi.org/10.2991/iac-17.2018.5.

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Tjandrakirana, Rina, and Ermadiani. "Factors That Influence Companies to Transfer Pricing." In 5th Sriwijaya Economics, Accounting, and Business Conference (SEABC 2019). Paris, France: Atlantis Press, 2020. http://dx.doi.org/10.2991/aebmr.k.200520.063.

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Belykh, Vladimir, and Tatyana Stadnik. "Improving the Procedures for Concluding Transfer Pricing Agreements in Russia and Kazakhstan: a Comparative-Legal Analysis." In The XX International Scientific Conference "Functioning of Investments Financed from State Resources and from Other Sources in The Countries of Central And Eastern Europe". Temida 2, 2022. http://dx.doi.org/10.15290/ipf.2022.01.

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The article provides a comparative analysis of the procedure for considering and concluding transfer pricing agreements in the countries of the Organization for Economic Cooperation and Development, the Russian Federation and the Republic of Kazakhstan. The issues of determining the parties to the transfer pricing agreement, introducing amendments and additions to them, the timing of the final decision on the application of entrepreneurs to conclude an agreement, as well as the list of documents required for its signing are to be investigated. The discussions of civil scientists regarding the interpretation of the nature of agreements on pricing, namely, referring them to one of the types of tax control or to a contractual form of regulation of relations in the field of taxation have been studied and reflected. The positive and negative aspects of transfer pricing agreements for the state and business have been identifi ed. It is noted that pricing agreements can help achieve a balance of public and private interests, neutralize the negative aspects of the use of transfer prices, including reducing numerous disputes and litigation between entrepreneurs and government agencies. Proposals were made to amend and supplement the legislation on transfer pricing in Russia and Kazakhstan in terms of improving the procedure for concluding transfer pricing agreements for tax purposes.
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Ruo-peng, Wang, Tang Xiao-wo, and Mu Yinping. "Strategic Transfer Pricing for Products/Services under Oligopoly." In 2006 International Conference on Service Systems and Service Management. IEEE, 2006. http://dx.doi.org/10.1109/icsssm.2006.320634.

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SAVA, Valentin, and Manuela Violeta TUREATCA. "Transfer Pricing between Optimization and International Tax Evasion." In 18th edition of the Conference “Risk in Contemporary Economy” RCE2017, June 9-10, 2017, Galati, Romania. LUMEN Publishing House, 2017. http://dx.doi.org/10.18662/lumproc.rce2017.1.51.

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"Analysis on Transfer Pricing of Multi-national Corporation." In 2018 International Conference on Economics, Politics and Business Management. Francis Academic Press, 2018. http://dx.doi.org/10.25236/icepbm.2018.03.

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Rajin, Danica, and Tijana Radojević. "The Application of Transfer Pricing Between Related Parties." In Sinteza 2016. Belgrade, Serbia: Singidunum University, 2016. http://dx.doi.org/10.15308/sinteza-2016-359-363.

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Sari, Dewi Kartika. "Transfer Pricing Aggressiveness and Corporate Governance: Indonesia’s Evidence." In 3rd International Conference on Vocational Higher Education (ICVHE 2018). Paris, France: Atlantis Press, 2020. http://dx.doi.org/10.2991/assehr.k.200331.123.

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Reports on the topic "Transfer pricing"

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Missbach, Leonard, Jan Christoph Steckel, and Adrien Vogt-Schilb. Cash transfers in the context of carbon pricing reforms in Latin America and the Caribbean. Inter-American Development Bank, November 2022. http://dx.doi.org/10.18235/0004568.

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One reason carbon prices are difficult to implement is that they might imply high additional costs on poor and vulnerable households. In response, studies often highlight that recycling revenues through cash transfers can render carbon pricing reforms progressive. This neglects that existing cash transfer programs target households from low-income groups often imperfectly and that impacts of a carbon price are heterogeneous within income groups. In this study we analyze the role of existing cash transfer schemes to alleviate distributional effects of carbon pricing in 16 Latin American and Caribbean countries. We find carbon pricing to be regressive in 11 countries, progressive in 5, and show that differences within income groups exceed differences between them. Beyond total household expenditures, car ownership and cooking fuel explain the variance in carbon pricing impacts. We show that households who are most affected by carbon pricing, some of them poor, do not necessarily have access to existing cash transfer programs. Governments aiming to compensate households may broaden coverage of existing cash transfer programs or consider complementing instruments such as in-kind transfers or removing existing distortionary taxes.
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2

Vet, Cassandra. Diffusion of OECD Transfer Pricing Regulations in Eastern Africa: Agency and Compliance in Governing Profit-Shifting Behaviour. Institute of Development Studies, May 2023. http://dx.doi.org/10.19088/ictd.2023.024.

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Kenya, Uganda and Rwanda introduced transfer pricing regulations into national law in 2006, 2011 and 2020 respectively, and invested in transfer pricing audits to reduce profit shifting by multinational enterprises (MNEs). These countries used the dominant OECD transfer pricing guidelines as a template for reform – the wisdom of this approach is contested. Critical authors stress that Western states largely dominate rule-setting procedures, and that costly transfer pricing enforcement drains the scarce resources of revenue authorities. How can we reconcile the critical perspective in global debates with the roll-out of OECD-type transfer pricing regimes on the ground?
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3

Bernard, Andrew, J. Bradford Jensen, and Peter Schott. Transfer Pricing by U.S.-Based Multinational Firms. Cambridge, MA: National Bureau of Economic Research, August 2006. http://dx.doi.org/10.3386/w12493.

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4

Clausing, Kimberly. The Impact of Transfer Pricing on Intrafirm Trade. Cambridge, MA: National Bureau of Economic Research, August 1998. http://dx.doi.org/10.3386/w6688.

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5

Hines, James. The Transfer Pricing Problem: Where the Profits Are. Cambridge, MA: National Bureau of Economic Research, December 1990. http://dx.doi.org/10.3386/w3538.

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6

Tilahun, Nathanael, and Abebe G. Yihdego. Unsuccessful Implementation of the OECD Transfer Pricing Guidelines in Low-Income Countries: The Case of Ethiopia. Institute of Development Studies, May 2024. http://dx.doi.org/10.19088/ictd.2024.033.

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This policy brief is extracted from a full-fledged research report financed by the International Centre for Tax and Development through the Ethiopian Tax Research Network and published in the British Tax Review, Issue 2, 2023. 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 multinational enterprises. The outcome of such assistance in the case of Ethiopia has been generally disappointing. Despite more than a decade of effort and nearly two decades since the initial introduction of transfer pricing rules in the tax system, the Ethiopian tax administration has not successfully completed a single transfer pricing audit. Three country-specific factors explain the poor implementation of transfer pricing rules in Ethiopia: the inability of tax officers to adapt from long-standing practices that run counter to OECD Guidelines, institutional ambiguity and rivalry among tax policy and enforcement organs, and the possibility of mock compliance with international standards without there being any such compliance in practice. Resolving some of the critical changes requires external technical assistance and decisive internal political and technocratic leadership, among other things.
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7

Vet, Cassandra. Diffusion of OECD Transfer Pricing Regulations in Eastern Africa: Agency and Compliance in Governing Profit-Shifting Behaviour. Institute of Development Studies, April 2023. http://dx.doi.org/10.19088/ictd.2023.022.

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Eastern African countries have codified transfer pricing regulations in their efforts to ring fence corporate tax revenue against profit shifting by multinational companies. Kenya (in 2006), Uganda (2011) and Rwanda (2020) used the dominant OECD transfer pricing guidelines as a template for reform. The wisdom of this approach for developing countries is contested in academic and civil society literature. According to this view, Western states largely dominate rule-setting procedures, and the costly enforcement of transfer pricing drains the scarce resources of revenue authorities. How can we reconcile the critical perspective in global debates with the roll-out of OECD type transfer pricing regimes on the ground? Case study evidence collected in these countries reveals that policymakers prefer anti-avoidance measures that are widespread and considered global practice. The widespread adoption of OECD transfer pricing norms worldwide gives them a unique compatibility advantage – this allows governments to adopt them as a way to raise public revenue, without compromising their attractiveness to investors. These network externalities are among the powerful lock-in effects that have cemented the position of the OECD guidelines in global tax governance. This study complements this narrative with a more bottom-up perspective. This highlights how domestic coalitions drive support for the OECD framework by mobilising both ideational and economic network effects. From this perspective the OECD rules are still an authoritative focal point for policymakers because interested social groups leverage concern about investor attractiveness. Ideational incentives shape bureaucratic policy advice to OECD standards. Civil society organisations, despite their critical stance towards the OECD guidelines at a global level, did not coalesce around a specific alternative – and instead raised the urgency of increasing public revenue.
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8

Bradford, David. Addressing the Transfer-Pricing Problem in an Origin-Basis X Tax. Cambridge, MA: National Bureau of Economic Research, July 2003. http://dx.doi.org/10.3386/w9843.

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9

Gordon, Roger, and Jeffrey MacKie-Mason. Why Is There Corporate Taxation In a Small Open Economy? The Role of Transfer Pricing and Income Shifting. Cambridge, MA: National Bureau of Economic Research, March 1994. http://dx.doi.org/10.3386/w4690.

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10

Navajas, Fernando. Electricity Rate Structure Design in Latin America: Where Do We Stand? Where Should We Go? Inter-American Development Bank, September 2023. http://dx.doi.org/10.18235/0005102.

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This paper reviews some critical issues for addressing the structure of electricity tariffs for ulterior purposes of policy research agenda. Starting from economic principles behind electricity tariff design, this paper asks what options ahead Latin America has in terms of improving electricity tariff design from a heterogeneous status quo, where trade-offs among cost recovery, cost reflectivity and affordability stand out. Options look like an avenue for improving cost recovery through better wholesale market design and regulation; move outside excess volumetric pricing and towards fixed and capacity charges; reduce excessive increasing block pricing; promote metering and regulatory flexibility for menu pricing with optional schemes and guaranteed bills; foster flexibility for new customer clustering and pricing to accommodate innovation in the energy transition; attend affordability with lump sum transfers through differentiated fixed charges and taxes and reform taxation to coordinate tariff format reform across different regulatory jurisdictions. Above all these dimensions, countries should coordinate on common information standards on the level and structure of electricity rates.
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