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Journal articles on the topic 'Transfer pricing'

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Author: Grafiati

Published: 4 June 2021

Last updated: 30 July 2024

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1

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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2

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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3

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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4

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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5

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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6

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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7

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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8

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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9

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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10

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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11

Illahi, Ilham, Nini Sumarni, and Zikrawahyuni Maiza. "Transfer pricing and tax avoidance: Moderating role of audit quality." JIFA (Journal of Islamic Finance and Accounting) 5, no. 2 (June 22, 2023): 89–97. http://dx.doi.org/10.22515/jifa.v5i2.6537.

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Transfer pricing can confer advantages to companies, such as enhancing their business competitiveness and facilitating internal fund transfers. However, in practical application, companies also exploit transfer pricing for the purpose of tax avoidance, aiming to minimize their tax liabilities. Consequently, this practice has been observed to have adverse implications for the state, specifically in terms of reduced tax revenue. To explore the impact of transfer pricing on tax avoidance, researchers undertook an empirical examination. They introduced the variable of audit quality as a moderator to assess its influence on the relationship between transfer pricing and tax avoidance. The study focused on a sample of manufacturing firms listed on the Indonesia Stock Exchange, employing a purposive sampling technique. To ascertain the effects of transfer pricing variables on tax avoidance and the moderating influence of audit quality, the researchers conducted multiple linear regression tests. The findings of the study indicate a positive association between transfer pricing and tax avoidance. This research provides valuable contributions that companies engaging in transfer pricing practices are, indeed, employing them as a form of tax avoidance strategy, aiming to minimize their corporate tax obligations. However, the study does not provide evidence supporting the notion that the quality of auditors can mitigate transfer pricing undertaken for the purpose of tax avoidance.

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12

DWORIN, LOWELL. "TRANSFER PRICING ISSUES." National Tax Journal 43, no. 3 (September 1, 1990): 285–91. http://dx.doi.org/10.1086/ntj41788846.

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13

Sansing, Richard. "International Transfer Pricing." Foundations and Trends® in Accounting 9, no. 1 (2014): 1–57. http://dx.doi.org/10.1561/1400000037.

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14

Kujawski, Jarosław. "MULTIPLE TRANSFER PRICING." PRACE NAUKOWE UNIWERSYTETU EKONOMICZNEGO WE WROCŁAWIU, no. 513 (2018): 253–64. http://dx.doi.org/10.15611/pn.2018.513.23.

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15

Schlossmacher, Stefan. "Insurance Transfer Pricing." Intertax 27, Issue 1 (January 1, 1999): 30–33. http://dx.doi.org/10.54648/taxi1999005.

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16

Schöler, Carina. "Transfer Pricing Manager." Controlling 25, no. 11 (2013): 644–45. http://dx.doi.org/10.15358/0935-0381_2013_11_644.

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17

Alles, Michael, and Srikant Datar. "Strategic Transfer Pricing." Management Science 44, no. 4 (April 1998): 451–61. http://dx.doi.org/10.1287/mnsc.44.4.451.

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18

Ronen, Joshua. "Transfer pricing reconsidered." Journal of Public Economics 47, no. 1 (February 1992): 125–36. http://dx.doi.org/10.1016/0047-2727(92)90008-4.

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19

Khris, Barnes, and Messina Whiteside. "Transfer Pricing: Purpose of Determination and Factors Affecting Transfer Pricing Determination." Journal Dimensie Management and Public Sector 1, no. 2 (December 23, 2020): 27–34. http://dx.doi.org/10.48173/jdmps.v1i2.48.

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The study discusses several things, including the factors that influence the determination of transfer pricing and the methods used in determining transfer pricing. Factors that influence transfer pricing include tax considerations, dance calculations, competitive factors, environmental risk, calculation of performance appraisals and accounting contributions. The method used in determining transfer pricing. Methods in determining transfer pricing include traditional methods, traditional methods consist of several ways including the comparable uncontrolled price method, cost-plus method, and resale price method. Transactional profit method: split profit and transactional net margin method.

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20

Balkish, Renata Violetta, Trijoko Prasetyo, and Basuki Wibowo. "ANALISIS HUBUNGAN MANAJEMEN PAJAK, SELISIH KURS DAN KEPEMILIKAN ASING DENGAN TRANSFER PRICING PERUSAHAAN." Jurnal Akuntansi dan Keuangan 25, no. 1 (January 20, 2020): 43–53. http://dx.doi.org/10.23960/jak.v25i1.194.

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Transfer pricing is the company's policy in determining the transfer price of related parties transaction. The purposed of this research is to get empirical evidence about the correlation of tax management, exchange rate, and foreign ownership with transfer pricing’s company. Independent variables used in this research are tax management, exchange rate and foreign ownership. Dependent variable of this research is transfer pricing. The population in this research are mining companies and miscellaneous industries listed on the Indonesia Stock Exchange (IDX) in 2014-2018. The method used for determining the sample is purposive sampling method.Sample consists of 67 observations. Data analysis using correlation pearson test with IBM SPSS Statistics 23 program as an analysis tool. The research results show that tax management has positive correlation with transfer pricing’s company.However, exchange rate and foreign ownership have no correlation with transfer pricing’s company.

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21

Olika, Daniel, and Ilemobade Olateru-Olagbegi. "Assessing the Transfer Pricing Disputes Framework in Nigeria." Business Law Review 43, Issue 2 (April 1, 2022): 65–76. http://dx.doi.org/10.54648/bula2022010.

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Transfer pricing, from documentation to audit, can be complicated and costly. Despite the release of transfer pricing regulations and increased scrutiny over intercompany dealings, the revenue authorities and taxpayers still disagree over various aspects of transfer pricing documentation. This situation necessitated the creation of various transfer pricing dispute resolution and dispute prevention mechanisms in jurisdictions across the globe. The Organization for Economic Cooperation and Development (OECD) has set the global standards on the mechanisms for transfer pricing dispute resolution/prevention and how they should apply. These transfer pricing dispute prevention mechanisms seek to avoid the costly and complicated process that is associated with transfer pricing audit while the transfer pricing dispute resolution mechanisms seek to resolve transfer pricing disputes in the most efficient manner. Accordingly, this article seeks to assess the transfer pricing dispute resolution/prevention framework in Nigeria against the global standards for resolving and preventing transfer pricing disputes. Transfer pricing, safe harbour, advanced pricing arrangement, mutual agreement procedure, dispute resolution, dispute prevention

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22

Jafri, Hasan Effendi, and Elia Mustikasari. "Pengaruh Perencaan Pajak, Tunnneling Incentive dan Aset Tidak Berwujud Terhadap Perilaku Transfer Pricing pada Perusahaan Manufaktur yang Memiliki Hubungan Istimewa yang Terdaftar di Bursa Efek Indonesia Periode 2014-2016." Berkala Akuntansi dan Keuangan Indonesia 3, no. 2 (December 31, 2018): 63. http://dx.doi.org/10.20473/baki.v3i2.9969.

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This aim of this research is testing effect of tax planning, incentive tunneling and intangible assets to transfer pricing behavior as measured by sales of related parties divided by sales of non-related parties. Tax planning is measured by Cash ETR, incentive tunneling measured by related party parties divided by total assets and intangible assets measured by total intangible assets divided by total sales. The population in this study is a manufacturing company listed on the Indnesia Stock Exchange 2014-2016. Determination of selected sample in research using purposive sampling method. Examination of influence of tax planning, incenntive tunnneling and intangible asset to behavior of transistor pricinng analyzed using softwareSPSS 20.0. The results showed that there were 134 companies meeting the sample criteria. Based on the results of multiple linear regression analysis with 5% significance, the results of this study concluded that: (1) tax planning affect the behavior of transfer pricing (2) incentive tunneling affect the transfer pricing behavior (3) intangible assets have no effect the transfer pricing behavior.

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23

Hanninen, Aleksei. "To What Extent Business Restructurings Fall within the Scope of Transfer Pricing Regulations in Russia?" Intertax 43, Issue 11 (November 1, 2015): 742–55. http://dx.doi.org/10.54648/taxi2015069.

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While Russia's new transfer pricing rules regulated in Chapter V.1 of the Tax Code definitely provide improvements to several transfer pricing issues, many interesting and timely transfer pricing questions, in particular business restructurings, still remain unsolved in the Tax Code. As transfer pricing of business restructurings has not been directly discussed in the Russian case law either, the current legal state in this respect should be considered very ambiguous. In this article, I will discuss to what extent business restructurings may fall within the scope of transfer pricing regulations in Russia. One of the main questions is should the business restructurings be examined as transfers of a going concern or should all the assets transferred in the course of business restructuring be reviewed separately. In addition, while the Tax Code's new transfer pricing rules are to a large extent based on the OECD Transfer Pricing Guidelines, it has its own peculiarities which may be considered troublesome especially from the view point of business restructurings. For instance, the arm's length principle regulated in the Tax Code is applied only to controlled transactions where commodities, services and/or work are being transferred between related parties. As it is very common in business restructurings that intangible assets, e.g., trademarks, goodwill and know-how, are transferred from one company to another, the Tax Code's provision cannot easily be applied to business restructurings.

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24

Momsen, J. H. "Transfer Pricing in Australia – Documenting and Defending Your Transfer-Pricing Policy." Intertax 27, Issue 4 (April 1, 1999): 136–48. http://dx.doi.org/10.54648/taxi1999025.

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25

Hutajulu, Dual Saper, and Khomsiyah Khomsiyah. "The Influence of Salaries, Production Costs and Tax Costs on Transfer Pricing in Companies Registered at Bureau Van Dijk-Osiris In 2022." Jurnal Indonesia Sosial Sains 4, no. 09 (September 25, 2023): 948–68. http://dx.doi.org/10.59141/jiss.v4i09.892.

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This study aims to determine the influence of Salary Expenses, Production Costs and Tax Expenses partially and simultaneously on Transfer Pricing, while the object of this study is a multinational company (Tbk) which is listed on the Van Dijk-Osiris Bureau 2022. Salary has a positive relationship to Transfer Pricing, so Salary Expense has no effect on Transfer Pricing which illustrates that when Salary Expense increases then Transfer Pricing practice decreases. This study aims to determine the influence of Salary Expenses, Production Costs and Tax Expenses partially and simultaneously on Transfer Pricing, while the object of this study is a multinational company (Tbk) that is listed on the Van Dijk-Osiris Bureau 2022. Salary has a positive relationship to Transfer Pricing, so Salary Expense has no effect on Transfer Pricing which illustrates that when Salary Expense increases then Transfer Pricing practice decreases. Production Costs have a positive relationship to Transfer Pricing, but the value is relatively small below 0.5 so the results of the Hypothesis test show that the Production Costs variable has no effect on Transfer Pricing which illustrates that when Production Costs increase, Transfer Pricing practices decrease. Tax Fees have a negative relationship to Transfer Pricing while the results of the hypothesis test show a significance value greater than 0.05, that Tax Fees have no effect on Transfer Pricing which illustrates that when Tax Expenses increase then Transfer Pricing practices will be low.

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26

Brauner, Yariv. "Formula Based Transfer Pricing." Intertax 42, Issue 10 (October 1, 2014): 615–31. http://dx.doi.org/10.54648/taxi2014055.

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The article discusses the choice between the current arm's length based transfer pricing regime and a formula-based transfer pricing regime. It argues that a reform of our transfer pricing rules is imminent, even if it is not part of a comprehensive reform of the international tax regime (a necessary yet a more complex goal to meet). The article demonstrates that many of the objections to a formula-based transfer pricing reform may be valid in the context of the more comprehensive reform of the business income tax rules, but not, or to a lesser extent, in the context of the narrower transfer pricing reform. It concludes therefore that much of the objection to formulary apportionment becomes irrelevant in a narrower scoped reform, and that the ground is ripe for it.

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27

Kumar, Manoj. "Sub-Supplier's Decision Affect Supply Chain Performance." International Journal of Applied Logistics 6, no. 2 (July 2016): 1–32. http://dx.doi.org/10.4018/ijal.2016070101.

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This paper studies how transfer pricing schemes interact with sub suppliers' opportunistic behaviors to affect supply chain performance. Effective supply chain management requires careful consideration of sub-suppliers', especially with respect to transfer pricing issues. Firms increasingly approach their sub-suppliers to drive compliance with firms' defined transfer pricing schemes. The paper models the supply chain incorporating asymmetric information among all the parties, supplier's innovation activities, sub suppliers' corruption possibility, and transfer pricing schemes. It examines the impact of various transfer pricing schemes on supply chain efficiency. Specifically, it conducts a performance comparison between the variable-cost transfer pricing scheme and the full-cost transfer pricing scheme. The paper finds that the sub supplier's choice of a transfer pricing scheme affects the supplier's sourcing decisions and the supply chain performance, and the variable-cost transfer pricing scheme performs better in achieving supply chain coordination. Therefore, the present research seeks to explore and increase one's understanding of critical factors that contribute to overcome aforementioned complexities and unique challenges of managing sub-suppliers for transfer pricing schemes. The present research expands on the theory of transfer pricing schemes and sub-supplier management context.

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28

Apriyanti, Hani Werdi, Suzana Sulaiman, and Adibah Jamaluddin. "Conceptualizing the MNEs Transfer Pricing Behavior: Indonesian Tax Authority Perspective." Accounting and Finance Research 13, no. 2 (May 15, 2024): 119. http://dx.doi.org/10.5430/afr.v13n2p119.

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Indonesian tax authorities currently encounter a lack of cooperative compliance among companies engaged in transfer pricing practices with their affiliated entities across borders. Transfer pricing is commonly associated with tax purposes, such as tax planning or avoidance, which is considered standard practice for business entities. Hence, there is a significant necessity to assess and evaluate the prevalence of tax planning or avoidance through transfer pricing in multinational enterprises operating in Indonesia. To gauge the extent of transfer pricing used for tax avoidance purposes, this study examines the perspective of tax authorities on companies' transfer pricing optimization behavior. Employing a qualitative approach, the study aims to comprehend the utilization of transfer pricing and its implications. The findings provide insights into transfer pricing behavior within companies over time. According to tax authorities, companies are motivated by the benefits of transfer pricing, including revenue optimization, corporate profit allocation, and cost optimization. However, these practices are influenced by various factors that facilitate or constrain transfer pricing activities. Multinational enterprises demonstrate limited awareness of normative beliefs regarding international and domestic transfer pricing regulations. Notably, companies affiliated with large multinational enterprises, possessing a strong understanding of transfer pricing, exhibit a high potential for tax planning or avoidance through transfer pricing arrangements with related parties. These findings contribute to the existing body of research on transfer pricing practices from the perspective of tax authorities as part of the Indonesian government.

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29

Moshkovska, Olena. "Main methodological principles of transfer pricing rules for financial transactions of the enterprises." Galic'kij ekonomičnij visnik 78-79, no. 5-6 (2022): 65–74. http://dx.doi.org/10.33108/galicianvisnyk_tntu2022.05_06.065.

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The article examines the theoretical aspects of transfer pricing in Ukraine. Threats of offshoring the banking system of Ukraine to create conditions for the abuse of transfer pricing in order to optimize taxation are considered. The rules of transfer pricing for financial transactions were studied and systematized based on the study of the recommendations of the Organization for Economic Cooperation and Development. Goal. The purpose of the study is to systematize the rules of transfer pricing for financial transactions in Ukraine to minimize the conditions for the erosion of the tax base of the participants of domestic financial and industrial groups. Methods. Research methods are general scientific methods of cognition, in particular, the article uses methods of empirical analysis to study the main concepts of research, comparison methods to compare legislative requirements regarding transfer pricing; graphic methods for building a structural and logical diagram of transfer pricing rules for financial transactions; methods of systematization and generalization for the systematization of transfer pricing rules for financial transactions. The results. The work outlines the shortcomings of the national legislation regarding the regulation of transfer pricing for financial transactions, identifies the risks of offshoring the banking system of Ukraine regarding the abuse of transfer pricing during financial transactions, systematizes the rules of transfer pricing for financial transactions, and characterizes the main methods of control over transfer pricing for financial transactions. The rules for the regulation of transfer pricing for financial transactions have been determined, which include: the exact delimitation of financial transactions, the assessment of treasury functions, cash pooling, financial guarantees, risk hedging and captive insurance. The mechanism for evaluating a financial transaction for its compliance with transfer pricing criteria is outlined. The rules and methods of assessing transfer pricing for financial transactions can be used to adapt domestic legislation to the global practice of transfer pricing regulation.

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30

Dinca, Mimar Husnaliana, and Vita Elisa Fitriana. "DO R&D EXPENDITURE, MULTINATIONALITY AND CORPORATE GOVERNANCE INFLUENCE TRANSFER PRICING AGGRESSIVENESS?" JURNAL AKUNTANSI DAN BISNIS : Jurnal Program Studi Akuntansi 5, no. 2 (November 29, 2019): 102. http://dx.doi.org/10.31289/jab.v5i2.2633.

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This research aims to examine the influence of R&D expenditure, multinationality and corporate governance (independent commissioners and shareholders ownership) toward transfer pricing aggressiveness. The prior study recommends determining the factors that affecting transfer pricing aggressiveness in different jurisdictions. Transfer pricing aggressiveness in this research is shown by transfer pricing index, which is the disclosure of transactions with related parties relating to transfer pricing. This research uses 63 multinational companies listed on Indonesia Stock Exchange from 2016-2017. The results indicate regression analysis research and development expenditures have no influence toward transfer pricing aggressiveness. Meanwhile, multinationality has a positive influence on transfer pricing aggressiveness. Moreover, corporate governances represented by independent commissioners and shareholders ownership have negative influences on transfer pricing aggressiveness.

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31

Aulia, Sandra. "Comparative Studies of Tax Administration on Transfer Pricing." Journal of Governance and Administrative Reform 5, no. 1 (June 30, 2024): 39–51. http://dx.doi.org/10.20473/jgar.v5i1.57398.

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Abstract Transfer pricing practices are employed for tax avoidance by shifting profits through transactions with related parties. This study aims to provide recommendations for Indonesia's transfer pricing tax administration by examining the transfer pricing practices of Australia, the United Kingdom, the United States, China, Japan, Singapore, and South Africa. This research adopts a qualitative approach using literature review and descriptive statistics from the countries included in the study sample. The findings of this study indicate ten considerations for reconstructing transfer pricing administration: tax authorities should have relevant and reliable comparable data, collaborate with other entities to acquire comparable databases, optimally utilize the Automatic Exchange of Information for Country by Country Reports, leverage technology, enhance the skills of the tax authority and taxpayer personnel, establish an Alternative Dispute Resolution, consider using profit split method, promptly resolve transfer pricing issues and disclose Advance Pricing Agreement data, implement safe harbor rules, and educate taxpayers on transfer pricing regulations. Keywords: tax administration, tax avoidance, transfer pricing. Abstrak Praktik transfer pricing dilakukan untuk penghindaran pajak dengan pergeseran laba melalui transanksi dengan pihak yang memiliki hubungan istimewa. Penelitian ini bertujuan untuk memberikan rekomendasi administrasi pajak atas transfer pricing di Indonesia dengan melihat praktik transfer pricing yang dilakukan Negara Australia, Inggris, Amerika, Cina, Jepang, Singapura, Afrika Selatan. Penelitian ini menggunakan pendekatan kualitatif dengan menggunakan studi literatur dan statistik deskriptif dari negara-negara yang dijadikan sampel penelitian. Hasil dari penelitian ini menunjukan 10 pertimbangan dalam rekonstruksi administrasi transfer pricing yaitu otoritas pajak harus memiliki data pembanding yang relevan dan handal, menjalin kerjasama dengan entitas lain dalam perolehan database pembanding, memanfaatkan secara optimum Automatic Exchange of Information untuk Country by Country Report, memanfaatkan teknologi, meningkatkan keterampilan sumber daya manusia otoritas pajak dan wajib pajak, memiliki Alternative Dispute Resolution, mempertimbangkan penggunaan metode transfer pricing profit split, penyelesaian segera masalah transfer pricing dan mengungkapkan data Advance Pricing Agreement, menerapkan safe harbour dan mengedukasi pengetahuan wajib pajak atas aturan transfer pricing. Kata kunci: administrasi pajak, tax avoidance, transfer pricing

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Putra, Rio Johan, and Amalia Astani Rizkillah. "The Effect of Bonus Mechanisms, Good Corporate Governance on Transfer Princing with Tax Avoidance as Moderating." International Journal of Industrial Management 14, no. 1 (July 31, 2022): 543–57. http://dx.doi.org/10.15282/ijim.14.1.2022.7495.

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The purpose of this study is to examine the effect of the bonus mechanism, good corporate governance on transfer pricing with tax avoidance as a moderating variable. The research method used is quantitative with data collection through the official website of the Indonesian Stock Exchange (IDX) or the Indonesian Stock Exchange (IDX). The sampling method used is purposive sampling in which the determination of the sample is based on certain criteria. The results of the sample obtained were 10 companies in the food and beverage sub-sector listed on the Indonesian stock exchange in 2016 – 2020. The results of the test hypothesis prove that the bonus mechanism has no effect on transfer pricing. The board of directors has no effect on transfer pricing. Independent commissioners have an effect on transfer pricing. Institutional ownership has no effect on transfer pricing. the audit committee has no effect on transfer pricing. Tax avoidance has no effect on transfer pricing. Tax Avoidance cannot Moderate the effect of the bonus mechanism on transfer pricing. Tax Avoidance cannot Moderate the influence of the board of directors on transfer pricing. Tax Avoidance cannot Moderate the influence of independent commissioners on transfer pricing. Tax Avoidance can Moderate the effect of institutional ownership on transfer pricing. Tax Avoidance cannot Moderate the influence of the audit committee on transfer pricing.

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Kurnila, Alvia, Denny putri Hapsari, and Santi Octaviani. "Pengaruh Beban Pajak, Kepemilikan Asing, dan Ukuran Perusahaan Terhadap Transfer Pricing." "LAWSUIT" Jurnal Perpajakan 3, no. 1 (May 6, 2024): 54–64. http://dx.doi.org/10.30656/lawsuit.v3i1.1385.

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Penelitian ini bertujuan untuk memperoleh bukti empiris tentang Beban Pajak, Kepemilikan Asing, dan Ukuran Perusahaan terhadap Transfer Pricing. Variabel independen yang digunakan adalah Beban Pajak, Kepemilikan Asing, dan Ukuran Perusahaan. Variabel dependen yang digunakan adalah Transfer Pricing Populasi dalam penelitian ini adalah perusahaan makanan & minuman yang terdaftar di Bursa Efek Indonesia (BEI) pada periode 2013-2017. Sampel yang dikumpulkan menggunakan metode Purposive Sampling. Total 10 perusahaan ditentukan sebagai sampel. Metode analisis penelitian ini menggunakan regresi linier berganda. Hasil penelitian menunjukkan bahwa 1) Beban Pajak tidak berpengaruh signifikan terhadap Transfer Pricing; 2) Kepemilikan Asing tidak berpengaruh signifikan terhadap Transfer Pricing; 3) Ukuran Perusahaan berpengaruh signifikan terhadap Transfer Pricing; dan 4) Beban Pajak, Kepemilikan Asing, dan Ukuran Perusahaan tidak berpengaruh secara simultan terhadap Transfer Pricing. Kata kunci : Beban Pajak, Kepemilikan Asing, Ukuran Perusahaan, dan Transfer Pricing. This study aimed to get empirical evidence about the Tax Burden, Foreign Ownership and Transfer Pricing Firm's size. Independent variables used are Tax Burden, Foreign Ownership and Firm Size. The dependent variable used is Transfer Pricing The population in this study is the food & beverage companies listed in Indonesia Stock Exchange (BEI) in the period 2013-2017. Samples were collected using Purposive sampling method. A total of 10 companies was determined as a sample. The method of analysis of this study using multiple linear regression. The results showed that 1) Income Tax Expense no significant effect on Transfer Pricing; 2) Foreign Ownership no significant effect on Transfer Pricing; 3) Company Size significant effect on Transfer Pricing; and 4) Income Tax Expense, Foreign Ownership and Firm Size no effect simultaneously to the Transfer Pricing. Keywords : Tax Burden, Foreign Ownership, company size, and Transfer Pricing.

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Aliyah, Siti, and Ela Amelia. "Faktor Pendorong Perusahaan Melakukan Transfer Pricing." Jurnal Rekoginisi Ekonomi Islam 2, no. 02 (August 7, 2023): 27–40. http://dx.doi.org/10.34001/jrei.v2i02.675.

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Abstract This study aims to measure and analyze the effect of taxes, foreign ownership, company size and bonus mechanisms on transfer pricing in manufacturing sector companies listed on the Indonesia Stock Exchange in 2017-2020. The analytical method used is descriptive statistical analysis, classical assumption test, multiple linear regression analysis and hypothesis testing using the SPSS application. Determination of the sample in this study using purposive sampling technique so that the number of research samples obtained is 160 companies. The results of this study indicate that taxes have a positive effect on transfer pricing. This means that the higher the tax that must be paid, the more transfer pricing will increase. Foreign ownership has no effect on transfer pricing. This means that high or low foreign ownership will not increase transfer pricing. Firm size has a positive effect on transfer pricing. This means that the larger the size of the company, the more transfer pricing will increase. The bonus mechanism has no effect on transfer pricing. This means that the high or low bonus mechanism will not increase transfer pricing.

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Marheni, Marheni, Yunita Maharani, and Liya Ermawati. "TRANSFER PRICING MULTINATIONAL COMPANIES IN INDONESIA: THE ROLE OF GOOD CORPORATE GOVERNANCE (GCG), TUNNELING INCENTIVE AND LEVERAGE." Integrated Journal of Business and Economics 6, no. 3 (October 31, 2022): 198. http://dx.doi.org/10.33019/ijbe.v6i3.506.

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The aims of study were 1) to analyze the effect of Good Corporate Governance (GCG) on transfer pricing; 2) Analyzing the effect of tunneling incentive on transfer pricing and 3) Analyzing the effect of leverage on transfer pricing. The research population were multinational companies in the manufacturing sector in Indonesia at 2010-2019. Methods of analysis used multiple regression analysis. The results showed that 1) GCG had a positive and significant effect on the company's transfer pricing. Hypothesis H1 which states that GCG had a positive effect on the company's transfer pricing is proven: 2) Tunneling Incentive (TI) had a positive and significant effect on the company's transfer pricing. Hypothesis H2 which states that Tunneling Incentive (TI) had a positive effect on the company's transfer pricing is proven; 3) Leverage had not positive and significant effect on the company's transfer pricing. Hypothesis H3 which states that leverage has a positive effect on the company's transfer pricing is not proven.

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Huang, Chung-Jian, Chau-Jung Kao, So-De Shyu, and Chao-Hung Yu. "Transfer Pricing of Taiwan's Listing/OTC Enterprises Between Mainland China and Taiwan: Quantile Regression Analysis." Review of Pacific Basin Financial Markets and Policies 14, no. 01 (March 2011): 129–51. http://dx.doi.org/10.1142/s0219091511002160.

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The main purpose of this paper is to explore the issue of enterprise's transfer pricing which has been noticed by tax administrations of many nations in recent years. The academia has also striven to develop models for interpreting transfer pricing and assessing transfer pricing profit of enterprises. A precise model is applied in this study to interpret enterprise's transfer pricing in practice. Furthermore, this model is also used to assess the transfer pricing profit of listing/OTC electronics companies in Taiwan and study the factors affecting transfer pricing profit. The empirical results show that material expense ratio significantly impacts transfer pricing profit. Corporate income tax expenses are positively and significantly correlated with net incomes of corporate transfer pricing transactions. This study also finds that regardless of whether the net income of corporate transfer pricing transactions is high, medium, or low, the proportion of material costs is positively and significantly correlated with the net income of corporate transfer pricing transactions in all scenarios. Higher profit will be affected by exchange rate. This suggests that companies involved in wafer fabrication, IC packaging and testing, and DRAM packaging and testing (subcontractors with relatively low material costs) are less likely to be involved in transfer pricing decisions.

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Zielke, Rainer. "Transfer Pricing Planning with Accuracy and Control." Intertax 41, Issue 10 (October 1, 2013): 542–50. http://dx.doi.org/10.54648/taxi2013050.

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Traditionally the Comtax® System provides not only current in-depth information on numerous national systems of taxation, but also quantifies crossborder payment transfers, and thus allows both a quick access on relevant detail knowledge and a direct comparison of different scenarios. This has now been upgraded by the new Comtax solution for transfer pricing were the arm's length principle, the definition of related companies, transfer pricing methods, business restructuring and dispute resolution are taken into consideration. The theory of international tax planning provides objectives and concepts of international tax planning and demands expertise in current and reliable information - also on transfer pricing. Comtax® System and Comtax® TP Tool are now jointly able to cover all aspects of international tax planning.

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Adhika, Firdha Nanda, and Sartika Wulandari. "Pengaruh Beban Pajak, Mekanisme Bonus, Exchange Rate, dan Intangible Asset terhadap Keputusan Transfer Pricing." Ekonomis: Journal of Economics and Business 7, no. 1 (March 26, 2023): 246. http://dx.doi.org/10.33087/ekonomis.v7i1.900.

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Business development encourages companies to grow into multinational companies whose activities are not only centered on one country. In transactions carried out by multinational companies, it is possible for companies to manipulate transfer prices (transfer pricing). The practice of transfer pricing is carried out with the hope of reducing the tax burden and also minimizing the amount of tax that must be paid to the State. The purpose of this study is to determine the effect of the tax burden, bonus mechanism, exchange rate, and intangible assets on manufacturing companies listed on the Indonesia Stock Exchange during the 2018-2021 period. The sample selection method used was purposive sampling method and obtained a sample of 72 research data. The data analysis technique used is multiple regression analysis using SPSS 25 as a statistical tool for testing the hypothesis. The result of this studi indicate that the variable tax burden, bonus mechanism, and exchange rate have no effect on companies making transfer pricng decision. Meanwhile, the intangible assets variable has a significant influence on transfer pricing decisions.

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Buckley, Peter J., Alan M. Rugman, and Lorraine Eden. "Multinationals and Transfer Pricing." Economic Journal 95, no. 379 (September 1985): 813. http://dx.doi.org/10.2307/2233056.

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Lane, Morton N. "Pricing Risk Transfer Transactions." ASTIN Bulletin 30, no. 2 (November 2000): 259–93. http://dx.doi.org/10.2143/ast.30.2.504635.

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Should the pricing of reinsurance catastrophes be related to the price of the default risk embedded in corporate bonds?If not, why not?A risk is a risk is a risk, in whatever market it appears. Shouldn't the risk-prices in these different markets be comparable? More basically perhaps, how should reinsurance prices and bond prices be set? How does the market currently set them? These questions are central to the inquiry contained in this paper.Avoiding unnecessary suspense, our answers are: Yes, cat prices should be related to credit prices because both risks contain a characteristic trade-off between the frequency of and severity of adverse events. We leave the question of how prices should be set to others and focus on the empirical question of how they have been set by the markets. In the process, we develop a fairly robust pricing mechanism and explore its potential uses in many different contexts.The 1999 Insurance-Linked Securities (ILS) market (a.k.a., Cat Bond market) provides the empirical springboard to the discussion. The ILS market is only 4 years old. As such, it represents a new and unique intersection of reinsurance and financial markets. It provides a wonderful laboratory for exploring risk-pricing.The ILS market, still in its experimental phase, appears to require more generous (cheap) pricing of insurance risk than does the bond market of default risk. So much so that academics have begun to weigh in on the question of why. Previously, insurance pricing discussions had been confined to practicing insurance professionals, particularly actuaries. For finance professionals, insurance pricing, much less reinsurance pricing, seldom made the index of their financial texts – though even that is beginning to change.

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Lo, Vincci, Marc M. Levey, and Stephen Nelson. "Transfer Pricing in China." Intertax 31, Issue 3 (March 1, 2003): 107–16. http://dx.doi.org/10.54648/taxi2003024.

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Slim, Gargouri. "Transfer Pricing in Africa." Intertax 43, Issue 4 (April 1, 2015): 344–54. http://dx.doi.org/10.54648/taxi2015030.

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While tax stakeholders are globally attentive to BEPS reforms, African countries don't seem to be actively involved in such process. Although civil society organizations are campaigning that any reform in the international taxation system shall be led by United Nations Committees rather than OECD in order to involve developing countries to decide their destiny, African countries are themselves responsible of being excluded from an active involvement. In fact, a look on the current transfer pricing regulation within each African jurisdiction shows that only few countries have implemented a detailed Transfer pricing regulation and guidelines.

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Mattos, Sebastiao. "Transfer Pricing in Brazil." Intertax 26, Issue 6/7 (June 1, 1998): 221–24. http://dx.doi.org/10.54648/taxi1998042.

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Schnorberger, Stephan. "Euro and Transfer Pricing." Intertax 27, Issue 1 (January 1, 1999): 4–16. http://dx.doi.org/10.54648/taxi1999002.

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Pogorelova, Lioubov. "Trade and Transfer Pricing." Intertax 40, Issue 1 (January 1, 2012): 33–53. http://dx.doi.org/10.54648/taxi2012004.

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Although there may be difficulties, especially during challenging economic times, in applying profit-based regulations when an income tax dimension is considered, if a trade dimension is introduced, in some circumstances profit-based methods, such as the comparable profits method (CPM) or transactional net marginal method (TNMM), may be preferred transfer pricing methods for multinationals. The article provides a comprehensive overview of the profit-based methods CPM and TNMM, where advantages and disadvantages of these methods are considered, and differences between these two methods are pointed out. The article also introduces a conceptual framework for transfer price coordination in the context of income tax and customs laws and examines issues pertaining to harmonization of income tax and customs laws.

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Smallman, Alan, and Henri Adrien. "Inter‐Divisional Transfer Pricing." Management Decision 25, no. 2 (February 1987): 27–30. http://dx.doi.org/10.1108/eb001440.

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Globerman, Steven, Alan M. Rugman, and Lorraine Eden. "Multinationals and Transfer Pricing." Canadian Journal of Economics 20, no. 1 (February 1987): 209. http://dx.doi.org/10.2307/135251.

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Hufbauer, Gary. "Multinationals and Transfer Pricing." Journal of International Business Studies 18, no. 3 (September 1987): 120–21. http://dx.doi.org/10.1057/jibs.1987.45.

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Knowles, Lynette L., and Ike Mathur. "International Transfer Pricing Objectives." Managerial Finance 11, no. 2 (February 1985): 12–16. http://dx.doi.org/10.1108/eb013546.

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Eilon, Samuel. "A transfer pricing saga." Omega 15, no. 1 (January 1987): 1–6. http://dx.doi.org/10.1016/0305-0483(87)90046-6.

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