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Journal articles on the topic 'Arm's length principle'

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Published: 4 June 2021

Last updated: 25 July 2025

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1

Tanisha, Gisella, and Andang Wirawan Setiabudi. "STUDI KOMPARATIF PENERAPAN PRINSIP KEWAJARAN DAN KELAZIMAN USAHA PADA TRANSAKSI AFILIASI JASA MANAJEMEN SEBELUM DAN SESUDAH BERLAKUNYA PMK NOMOR 172 TAHUN 2023." BALANCE: Jurnal Akuntansi, Auditing dan Keuangan 21, no. 2 (2024): 145–76. https://doi.org/10.25170/balance.v21i2.6450.

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The Indonesian government released the latest regulation regarding the arm's length principle in transactions affected by special relationships, namely Peraturan Menteri Keuangan No. 172 (PMK-172), effective December 29, 2023. As a multinational company with related party transactions, PT XYZ must adjust to PMK-172 for the tax year after its enactment. Therefore, the author conducts a comparative analysis of applying the arm’s length principle before and after the enactment of PMK-172 to help PT XYZ ensure its tax compliance. This study aims to determine the suitability of arm’s length princip

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2

Dwarkasing, Ramon S. J. "The Concept of Associated Enterprises." Intertax 41, Issue 8/9 (2013): 412–29. http://dx.doi.org/10.54648/taxi2013038.

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The concept of Associated Enterprises is essential for the application of the arm's length principle, which is the internationally recognized tax standard for transfer pricing. The arm's length principle is the underlying principle of Article 9 of the Organisation for Economic Co-operation and Development (OECD) Model Tax Convention (OECD Model) and of transfer pricing laws of many countries. Virtually all tax treaties are based on the arm's length principle. As stated by Article 9 OECD Model, the arm's length principle is applied to Associated Enterprises. The concept of Associated Enterprise

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3

Sevtianti, Lola Serly, Gilbert Rely, Bambang Prayogo, Mulyadi, and Panata Bangar Hasioan Sianipar. "Pengaruh Capital Intensity, Likuiditas dan Prinsip Kewajaran & Kelaziman Usaha Terhadap Manajemen Perpajakan." Baashima : Jurnal Bisnis Digital, Akuntansi, Kewirausahaan, dan Manajemen 2, no. 1 (2024): 30–48. https://doi.org/10.61492/baashima.v2i1.76.

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The study aims to examine the effect of Capital Intensity, Liquidity and Arm's Length Principle on Tax Management. The population of mining sector issuers on the Indonesia Stock Exchange for the 2020-2022 period. The research used quantitative data, multiple linear regression, sampling techniques namely purposive sampling methods and obtained as many as 10 issuers and 30 data samples. Hypothesis testing with SPSS Statistics 27, the results concluded that (1) Capital Intensity had no affect on Tax Management, (2) Liquidity had no affect on Tax Management, (3) Arm's Length Principle have a signi

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4

Wuryaningsih, Heni, and Siti Nuryanah. "Why Is It Challenging to Apply Arm’s Length Principle on Intragroup Financing in Indonesia? A Tax Officials Perspectives." Jati: Jurnal Akuntansi Terapan Indonesia 7, no. 2 (2024): 151–66. http://dx.doi.org/10.18196/jati.v7i2.22716.

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Directorate General of Taxes amends its supervision business process to require Account Representatives to conduct transfer pricing analysis. As an international standard, transfer pricing must adhere to the arm's length principle. This research aims to analyze the reasons why the arm’s length principle on intragroup financing is challenging to apply in Indonesia, as perceived by Account Representatives in Jakarta Special Regional Tax Office utilizing the ADKAR model. Questionnaires and interviews are used as triangulation techniques in the study. The results show that participants were aware

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5

Robillard, Robert. "BEPS: Is the OECD Now at the Gates of Global Formulary Apportionment?" Intertax 43, Issue 6/7 (2015): 447–53. http://dx.doi.org/10.54648/taxi2015041.

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Several Base Erosion and Profit Shifting (BEPS) public discussion drafts recently released have indirectly called into question the relevance of the arm's length principle for transfer pricing and international taxation purposes. This article highlights the numerous instances where formulary-like approaches have lately been put forward by the OECD to replace the arm's length principle. Are we witnessing a major philosophical shift by the OECD?

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6

Jakoubek, Jiří. "Arm's Length Principle in Intangible Assets Valuation." Český finanční a účetní časopis 2013, no. 4 (2013): 70–83. http://dx.doi.org/10.18267/j.cfuc.353.

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7

Choe, Chongwoo, and Noriaki Matsushima. "The arm's length principle and tacit collusion." International Journal of Industrial Organization 31, no. 1 (2013): 119–30. http://dx.doi.org/10.1016/j.ijindorg.2012.12.001.

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8

Nerudová, D., and V. Solilová. "Transfer pricing in agricultural enterprises." Agricultural Economics (Zemědělská ekonomika) 57, No. 7 (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

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9

Bustos, Sebastián, Dina Pomeranz, José Vila-Belda, and Gabriel Zucman. "Challenges of Monitoring Tax Compliance by Multinational Firms: Evidence from Chile." AEA Papers and Proceedings 109 (May 1, 2019): 500–505. http://dx.doi.org/10.1257/pandp.20191045.

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This paper reviews common challenges of taxing multinational firms, using Chile as a case study. We briefly describe key international tax avoidance methods: profit shifting to low-tax jurisdictions through transfer pricing and debt shifting. We discuss the prevalent policy to tax multinationals--the arm's length principle--and alternative proposals using apportionment formulas. Novel data from Chile show that multinationals make up a large share of GDP but report lower profit and effective tax rates than local firms. In 2011, Chile implemented a reform following OECD guidelines to enforce the

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10

Becker, Helmut. "Losses and the Arm's-Length Principle: A German Approach." Intertax 25, Issue 8/9 (1997): 287–90. http://dx.doi.org/10.54648/taxi1997053.

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11

Yao, Jen-Te. "The arm's length principle, transfer pricing, and location choices." Journal of Economics and Business 65 (January 2013): 1–13. http://dx.doi.org/10.1016/j.jeconbus.2012.09.004.

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12

Lemein, Gregg D., Mary C. Bennett, and Caroline Silberztein. "The OECD Discussion Draft on the Transfer of Intangibles (Revision of Chapter VI of the OECD Transfer Pricing Guidelines) Main Comments." Intertax 41, Issue 2 (2013): 60–65. http://dx.doi.org/10.54648/taxi2013007.

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On 6 June 2012, the Organisation for Economic Co-operation and Development (OECD) released a discussion draft on the Proposed Revision of Chapter VI of the OECD Transfer Pricing Guidelines (TPG) and Related Provisions. Intertax publishes the full text of the discussion draft together with the comments submitted by members of Baker & McKenzie Global Transfer Pricing Practice and Global Tax Policy Group. While applauding the document for clarifying a number of important issues related to the application of the arm's length principle to situations involving intangibles, the commentators also

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13

CHOE, CHONGWOO, and CHARLES E. HYDE. "Multinational Transfer Pricing, Tax Arbitrage and the Arm's Length Principle*." Economic Record 83, no. 263 (2008): 398–404. http://dx.doi.org/10.1111/j.1475-4932.2007.00429.x.

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14

Keuschnigg, Christian, and Michael P. Devereux. "The arm's length principle and distortions to multinational firm organization." Journal of International Economics 89, no. 2 (2013): 432–40. http://dx.doi.org/10.1016/j.jinteco.2012.08.007.

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15

Kuzheliev, Mykhailo, and Iryna Syvolap. "Methods of determining compliance with the conditions of controlled operations of the "handout" principle." University Economic Bulletin, no. 54 (September 27, 2022): 144–49. http://dx.doi.org/10.31470/2306-546x-2022-54-144-149.

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The subject of the research is theoretical approaches to the application of methods of establishing the compliance of the conditions of controlled operations with the principle of "outstretched hand". The purpose of the article is to carry out an analysis of the existing methods of establishing the compliance of the conditions of economic transactions with the principle of "stretched hand" to prevent financial risks for economic entities based on a systematic approach. Method or methodology of research. The article uses methods of scientific abstraction, system method, methods of analysis and

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16

Glahe, Moritz. "Transfer Pricing and EU Fundamental Freedoms." EC Tax Review 22, Issue 5 (2013): 222–32. http://dx.doi.org/10.54648/ecta2013025.

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In this article, the author analyses the relation between national transfer pricing rules and the European Union (EU) fundamental freedoms. The article focuses on the discrimination/restriction analysis and the justification test. It is shown that the European Court of Justice (ECJ's) judgment in Société de Gestion Industrielle (SGI) is not the end of the discussion, but that discriminating national transfer pricing rules applying the arm's length principle have to fulfil several legal requirements in order to be justified. In this regard, a closer look is taken at the tax avoidance and balanc

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17

Storozhuk, Tetyana, and Artem Morhunenko. "Documentation of Transfer Pricing Transactions in the Accounting System of Multinational Enterprise Groups." Oblik i finansi, no. 1(107) (2025): 15–23. https://doi.org/10.33146/2307-9878-2025-1(107)-15-23.

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External factors and the complexity of the internal organizational structure can significantly affect the collection of evidence (information), which is the basis for assessing the compliance of controlled transactions with the arm's length principle by participants in multinational enterprise groups (MEGs). The article aims to improve the system of accounting and assessment of intragroup transactions of MEGs regarding the compliance of controlled transactions with the arm's length principle by developing document forms for reflecting information on business transactions. An analysis of scient

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18

Tambunan, Rafael, and Yulianti Abbas. "Evaluasi Implementasi Analisis Kesebandingan atas Sengketa Transfer Pricing PT OCI." Owner 7, no. 4 (2023): 2785–95. http://dx.doi.org/10.33395/owner.v7i4.1735.

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Transfer pricing is one of the most popular drivers of tax disputes between taxpayers and tax authorities around the world. To lessen the probability of disputes, the OECD proposes procedures for comparability analysis. These procedures help taxpayers and tax authorities to determine the arm's length values of related-party transaction, which is the main cause of many transfer pricing disputes. This study uses a case study method, focusing on PT OCI, to evaluate a firm’s comparative analysis practice and its conformity to OECD Transfer Pricing Guidelines. Data collection through interviews and

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Kraievskyi, Volodymyr, and Oleksandr Muravskyi. "TAX COMPLIANCE CONTROL AND AUDIT OF TRANSFER PRICING TRANSACTIONS." Економіка розвитку систем 6, no. 1 (2024): 37–45. http://dx.doi.org/10.32782/2707-8019/2024-1-5.

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The article presents the authors' vision of the features and mechanism of tax compliance control and audit in the management of transfer pricing operations. Effective interaction between business entities and tax authorities in the process of controlling and auditing transfer pricing transactions should be based on the principles of compliance with the help of two tools – assessment of the quality of transfer pricing policy and internal control system (as a result of interaction of internal and external control systems) and assessment of the quality and effectiveness of internal audit of trans

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20

Ardika, I. Kadek Agus, Putu Novia Hapsari Ardianti, and Cokorda Istri Agung Evita Nindia Putri. "The Arm's Length Principle in Mitigating Tax Avoidance: A Systematic Literature Review." International Journal of Applied Business and International Management 10, no. 1 (2025): 83–100. https://doi.org/10.32535/ijabim.v10i1.3673.

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This study examines the effectiveness of Transfer Pricing Documentation (TP Doc) in supporting the Arm’s Length Principle (ALP) to reduce tax avoidance through related-party transactions (RPTs), especially involving tax haven jurisdictions. Using a Systematic Literature Review (SLR) approach, 15 relevant studies published between 2015 and 2024 were analyzed. The literature was selected based on keywords such as “Profit Shifting,” “Tax Haven,” “Related Party Transaction,” “Tax Avoidance,” and “Transfer Pricing.” The findings indicate that TP Doc contributes significantly to enhancing transparen

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21

Besdy, Besdy, Pony Pony, Abraham Abraham, and Ariman Sitompul. "Comparison of Transfer Pricing methods and their application in disputed tax cases in Indonesian courts." Legalpreneur Journal 2, no. 2 (2024): 197–205. http://dx.doi.org/10.46576/lpj.v2i2.4402.

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Transfer pricing is a trending topic of taxation in various worlds, not least in Indonesia. Directorate General of Taxation is very aggressive to supervise and monitor the practices of transfer pricing conducted by the taxpayer, because it is not just a case of fictitious tax refunds and tax realtor practices that erode the potential for state revenue from taxes, but the practice of tax evasion in the process transfer pricing is also considered a lot of harm to tax revenue. Transfer pricing practice is actually a common practice and commonly practiced by companies group companies. However, thi

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22

de Hosson, Fred C. "Codification of the Arm's Length Principle in the Netherlands Corporate Income Tax Act." Intertax 30, Issue 5 (2002): 189–97. http://dx.doi.org/10.54648/407843.

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23

Muravskyi, Oleksandr. "METHODOLOGICAL TOOLS FOR MAKING MANAGEMENT DECISIONS ON TRANSFER PRICING." Економіка розвитку систем 5, no. 2 (2023): 4–15. http://dx.doi.org/10.32782/2707-8019/2023-2-1.

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The article systematises methodological tools for making managerial decisions on transfer pricing. An analysis of domestic scientific works on the study of the list of methodological tools for determining transfer prices is carried out. It is found that transfer pricing researchers in the system of management accounting agree on a list of methods for determining transfer prices, including methods for determining transfer prices on the basis of market prices, on the basis of cost prices determined by marginal/standard/full costs or on a double basis, and on the basis of contract prices. Researc

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24

Putri, Wika Arsanti. "PRINSIP KEWAJARAN DAN DOKUMEN SEBAGAI PENANGKAL KECURANGAN TRANSFER PRICING DI INDONESIA." Jurnal Riset Akuntansi dan Keuangan 6, no. 1 (2018): 1–10. https://doi.org/10.17509/jrak.v5i2.8029.

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Abstract. This research is a normative study based on legal principles, prevailing laws and regulations as well as studying the literature related to transfer pricing activities. Transfer pricing causes tax revenues in a country with high tax rates to feel aggrieved as the return on behalf of a company in that country is transferred to a country at a low tariff to avoid taxes. This becomes the problem of countries that must be looked for solutions so that taxation in every country is deemed fair over the earnings that are duly dressed in the company. In Indonesia in 2016 in overcoming it appli

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Wahyuningtias, Tri, Salsabila Phytagora Athariq, Kharisma Ika Nurkhasanah, Siti Aliza Nuraini Wahdini, Rahil Syira Roudhlotul Janah, and Yulianisa Amelia Fasya. "Analisis penghindaran pajak (tax avoidance) perusahaan multinasional (studi kasus PT Adaro Energy tbk)." Jurnal Ilmiah Bisnis dan Perpajakan (Bijak) 7, no. 1 (2025): 28–35. https://doi.org/10.26905/j.bijak.v7i1.15020.

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This study discusses the practice of tax avoidance through transfer pricing carried out by multinational companies, with a focus on the case of PT Adaro Energy Tbk. The aim of this research is to analyze the transfer pricing mechanism between PT Adaro Energy Tbk and its subsidiaries in Singapore, which has the potential to cause losses in state revenues. The research method used is qualitative, examining legal aspects, tax regulations and the application of the arm's length principle. The research results show that PT Adaro is suspected of carrying out transfer pricing by selling coal to its s

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O'Sullivan, Janet. "LOST ON PENALTIES." Cambridge Law Journal 73, no. 3 (2014): 480–83. http://dx.doi.org/10.1017/s0008197314000920.

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FREEDOM of contract is a fundamental principle of English law, but it is of course qualified by numerous protective regimes, some common law, most statutory nowadays, which protect vulnerable parties from untrammelled, unequal free bargaining. It is, quite rightly, exceptional for an experienced commercial party, negotiating at arm's length and with the benefit of specialist professional advice, to succeed in invoking such a regime to escape being bound by what he freely agreed. Yet, in Cavendish Square Holdings BV v Makdessi [2013] EWCA Civ 1539, this was precisely the controversial result.

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27

Saptono, Prianto Budi, and Ismail Khozen. "Abstracting the Debate over Fair Value Measurement and Arm's Length Principle: Implications for Tax Purposes." Jurnal Dinamika Akuntansi 14, no. 2 (2022): 167–79. http://dx.doi.org/10.15294/jda.v14i2.39155.

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Purpose: The requirement for a transaction price measurement system that accurately reflects actual value is becoming increasingly urgent as firms expand globally. The argument over the applicability of fair value (FV) and arm's length principle (ALP) arose since both are applicable concurrently due to their broad confluence. This study analyzes and synthesizes the similarities and distinctions, as well as the impact of FV and ALP on tax purposes.Method: The study is descriptive qualitative in nature. We gathered data through document analysis and in-depth interviews. Five informants from acad

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Sulik-Górecka, Aleksandra. "Dilemmas of Transfer Pricing Comparability Analysis in Manufacturing Entities. Polish-Czech Case Study." Management Systems in Production Engineering 26, no. 2 (2018): 76–82. http://dx.doi.org/10.2478/mspe-2018-0012.

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Abstract Modern manufacturing entities often operate in capital groups, and their role is sometimes limited to the function of cost centers. From the legal point of view, however, they are separate entities obliged to apply transfer pricing regulations. Meeting the requirements of the arm's length principle can be very difficult at this time, given the relationships and conflicts of interest in the capital group. Complexity increases in capital groups operating in different countries, due to differences in tax regulations. The main purpose of the paper is to demonstrate that the need to valuat

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Poulsen, Martin. "Freedom of Establishment and the Balanced Allocation of Tax Jurisdiction." Intertax 40, Issue 3 (2012): 200–211. http://dx.doi.org/10.54648/taxi2012023.

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The article analyses the case law of the Court of Justice of the European Union in relation to the different justification grounds that Member States can rely on in regard to restrictive national tax measures. The main purpose of the article is to reconcile the different justification grounds in order to present a (more) coherent approach to evaluating national anti-abuse legislation. It is submitted that the justification ground of 'balanced allocation of tax jurisdiction' and the arm's-length principle for allocation of income should form an important basis under EU law for the evaluation of

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Gargouri, Slim. "Transfer Pricing in North African Countries." Intertax 42, Issue 4 (2014): 290–92. http://dx.doi.org/10.54648/taxi2014029.

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In North African region, Only Egypt and Algeria have already implemented a Transfer Pricing regulation: Egypt introduced the concept in 2005 while the Algerian rules were implemented in 2007. Though, the measures in force are still under the urgent requirement to be improved: The Egyptian case shall focus on the transfer pricing documentation while Algeria has to further develop transfer pricing methods as well as to authorize the conclusion of Advance Pricing Agreement (APA). Tunisia and Morocco have not introduced transfer pricing rules yet, but they require that transactions between related

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Saragi, Daniel Edgar Hirasma. "DEVELOPMENT OF TRANSFER PRICING REGULATIONS IN INDONESIA." Jurnal Ilmu Ekonomi dan Pembangunan 24, no. 2 (2024): 77. https://doi.org/10.20961/jiep.v24i2.90934.

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This research driven by the urgency to understanding the massive improvement of transfer pricing regulations in Indonesia. Directorate General of Taxes (DGT) have adjusted along with the advancement of macroeconomic, business field, cross border trade, and domestic needs. This study aims to describe the development of transfer pricing regulations in Indonesia, since it was first enacted in 1983. The analysis covers three main topics, which are the implementation and examination of arm's length principle, transfer pricing documentation, and advance pricing agreement. This research used qualitat

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Li, Yongjun, Lin Lin, Qianzhi Dai, and Linda Zhang. "Allocating common costs of multinational companies based on arm's length principle and Nash non-cooperative game." European Journal of Operational Research 283, no. 3 (2020): 1002–10. http://dx.doi.org/10.1016/j.ejor.2019.11.049.

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Sanghavi, Dhruv. "Vodafone Transfer Pricing Decision: A Mistake of Judgment." Intertax 43, Issue 5 (2015): 428–36. http://dx.doi.org/10.54648/taxi2015039.

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On 10 October 2014, the Bombay High Court exercised its non-appellate jurisdiction to quash a transfer pricing claim in the case of Vodafone, in which the tax authorities sought to apply the arm's length principle to equity financing transactions. This interpretation has been accepted by the Government of India, which has decided not to appeal against the decision of the Bombay High Court. In this contribution, the author critically analyses the controversy to find that not only was the court's interpretation of the law potentially incorrect, but also that it decided the case out of turn, and

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A.E.Omoregie, P.E Eromosele, and F. U. Osazuwa. "AN OUTLINE OF INTERCONTINENTAL TRANSFER PRICING AND STATUTORY LAW." International Journal of Social Sciences & Economic Environment, ISSN: 2456-7485 1, no. 1 (2016): 01–12. https://doi.org/10.53882/IJSSEE.2016.0101001.

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ABSTRACT  <em>Multinational Corporations have seen transfer pricing as a handy tool to achieving their acceptable corporate objectives to the detriment of home/host countries through unethical movement of one country’s tax revenue to another, thus, making transfer pricing a top-of-mind concern for most Countries. In an attempt to fight perceived income shifting by Multinational Corporations (MNCs), some countries have enacted transfer pricing rules which are either in accordance with the widely adopted Organization for Economic Cooperation and Development (OECD) Transfer Pricing Gui

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Pyroha, S. S. "Transfer pricing reforms in the context of BEPS: challenges remain." Law and Safety 92, no. 1 (2024): 163–72. http://dx.doi.org/10.32631/pb.2024.1.15.

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The presence of affiliated entities in different countries and the independence of tax systems make it easy to shift profits from jurisdictions with high corporate tax rates to jurisdictions with low rates. Transfer prices and the arm's length principle are used to prevent profit shifting. The article identifies the peculiarities of transfer pricing reform in the context of the BEPS plan, analyses changes to Ukrainian legislation and opportunities for its improvement. The article analyses the amendments to the Tax Code of Ukraine aimed at ensuring the implementation of the BEPS plan. The

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Li, Jinyan, Nathan Jin Bao, and Huaning Christina Li. "Value Creation: A Constant Principle in a Changing World of International Taxation." Canadian Tax Journal/Revue fiscale canadienne 67, no. 4 (2019): 1107–34. http://dx.doi.org/10.32721/ctj.2019.67.4.sym.li.

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The authors consider the new nomenclature of value creation in terms of its meaning, theoretical basis, and importance in the context of the international taxation of business profits. The authors' central claim is that the principle of value creation is a profound elaboration of the doctrine of economic allegiance, which is the theoretical basis for the current international tax system; and that international tax norms, such as the arm's-length principle, are meant to give effect to the doctrine of economic allegiance (and now to the principle of value creation). As demonstrated by the Organi

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Maulana, Nabiil Ikbaar. "Pengaturan Pajak Penghasilan (PPh) Terkait Transfer Pricing yang Dilakukan oleh Perusahaan Multinasional." Jurist-Diction 5, no. 2 (2022): 695–710. http://dx.doi.org/10.20473/jd.v5i2.34906.

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AbstractThe rise of activities regarding transfer pricing carried out by multinational corporation has the potential to generate state revenue in the taxation sector. The government, in this case the Tax Authority, has taken several preventive measures so that multinational corporation do not practice transfer pricing outside the arm's length principle. The occurrence of differences of opinion that occurs between multinational corporation that act as taxpayers and the Tax Authorities often occurs due to the lack of provisions regarding transfer pricing. Provisions regarding taxation in Indones

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Quinn, Ruth‐Blandina M. "Distance or intimacy?—The arm's length principle, the British government and the arts council of Great Britain1." International Journal of Cultural Policy 4, no. 1 (1997): 127–59. http://dx.doi.org/10.1080/10286639709358066.

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Zielke, Rainer. "Transfer Pricing Planning with Accuracy and Control." Intertax 41, Issue 10 (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 co

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Ayvaz, Ednan. "Outsourcing as a solution of problems of transfer price in multiple companies: A case studyÇokuluslu şirketlerde transfer fiyatlandırması sorunlarının çözümü olarak dış kaynak kullanımı (outsourcing): Bir vaka çalışması." Journal of Human Sciences 14, no. 4 (2017): 4251. http://dx.doi.org/10.14687/jhs.v14i4.4963.

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The scope and complexity of international tax regulations on transfer pricing is largely focused on adhering to taxation rather than market competition. Outsourcing has been extensively described in order to comprehend it better for comparability functions and analysis, transfer pricing methods accepted by the OECD and the arm's length principle to identify similar transactions between independent parties. The aim of this study is to demonstrate the necessity of minimizing of the conflict between the tax auditors and multinational corporations and of the inefficiencies of tax rules and the arb

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Spelter, Henry. "If America Had Canada's Stumpage System." Forest Science 52, no. 4 (2006): 443–45. http://dx.doi.org/10.1093/forestscience/52.4.443.

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Abstract The North American lumber market is integrated and, under normal conditions, provides unhindered access to all suppliers. North American log markets, in contrast, function on different principles: in one principle, a profit allowance for the wood processor plays a role in timber pricing, whereas in the other it is a byproduct of the give-and-take of arm's length market negotiations. Under the first system, markets are characterized by high elasticities of price transmission and, at times of market weakness, by low elasticities of product supply. Under the second system, the opposite o

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Heilbron, Firgia Ekklesia. "Analisis Perubahan Ketentuan Transfer Pricing dalam Peraturan Menteri Keuangan No. 172 Tahun 2023 dengan Peraturan yang Digantikannya." EKOMA : Jurnal Ekonomi, Manajemen, Akuntansi 4, no. 3 (2025): 4958–70. https://doi.org/10.56799/ekoma.v4i3.6512.

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Minister of Finance Regulation (PMK) Number 172 of 2023 introduces significant reforms in tax policy, focusing on administrative simplification, enhanced transparency, and harmonization with international standards. This regulation replaces PMK 213 of 2016 and other regulations, which previously governed the arm's length principle in related-party transactions. PMK 172 expands the scope of regulation, strengthens the authority of tax officials, and provides more detailed documentation guidelines to support transfer pricing supervision. Furthermore, this regulation aligns tax policies with stra

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Ravn-Højgaard, Signe. "Media policy in Greenland." Nordicom Review 42, s2 (2021): 36–52. http://dx.doi.org/10.2478/nor-2021-0016.

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Abstract This article describes the historical development of media policy in Greenland, and the shifts in the underlying normative and causal ideas that legitimise media policy. I argue that media policy reflects changes in Greenland's political system. Specifically, under colonial rule, Greenlandic media was state run and media was seen as an instrument to educate the population. Gradually, with the introduction of home rule, a paradigm shift took place, whereby media was seen as a vital instrument to strengthen Greenlandic language and identity. At the same time, normative ideas of media in

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Damiran, Suvdaa, Tugsjargal Sereenendorj, Batbileg Dashnyam, Bayarmaa Dashnyam, and Nyamaa Dulamsuren. "Determining the loss of mining sector tax revenue: Evidence from Mongolia." Journal of Eastern European and Central Asian Research (JEECAR) 11, no. 2 (2024): 239–52. http://dx.doi.org/10.15549/jeecar.v11i2.1463.

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In recent years, due to significant tax revenue losses, transfer pricing has become an issue of concern for tax authorities, policymakers, and academics. In this study, the authors aim to analyze transfer pricing and its impact on fiscal revenue in the case of Mongolia, a developing country with a mining-dominated economy. In our research, we used the arm's length principle to determine transfer pricing and estimate the loss of corporate income tax due to transferring pricing; moreover, we compared the operating profit margin of Mongolia’s mining companies with the Far East and Central Asia Oc

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Hukamawati, Dinartika, and Arifah Fibri Andriani. "ANALISIS PENERAPAN ARM’S LENGTH PRINCIPLE PADA TRANSAKSI PEMBAYARAN ROYALTI ATAS PEMANFAATAN MEREK DAGANG (TRADEMARK) KEPADA PERUSAHAAN AFILIASI." INFO ARTHA 4 (May 24, 2017): 1–18. http://dx.doi.org/10.31092/jia.v4i4.34.

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Trademark is a unique marketing intangible. It does not only involve the expenses of marketing, advertising, and promoting, but the reputation of the trademark's owners also takes part in the development of trademark. Many parties involve in the development of trademark. In the context of transfer pricing, these parties entitle to some compensation. And arm's length principle must be applied to determine the reasonable compensation for the use of trademark. Transaction payment of royalties on trademarks is subject to taxes.The taxation of transactions payment of royalties on the use of the tra

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Suharsono, Agus, and Nanik Prasetyoningsih. "Coca-Cola Transfer Pricing Dispute: United States Case Analysis and Tax Policy Lessons for Indonesia." International Journal of Advance Social Sciences and Education (IJASSE) 2, no. 4 (2024): 321–38. http://dx.doi.org/10.59890/ijasse.v2i4.2348.

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Decision of the Coca-Cola transfer pricing dispute in the United States Tax Court, which resulted in tax underpayment, can be used as a lesson for Indonesia. This research method is doctrinal, with a law, case, concept and interpretation approach. The data studied is secondary data in the form of laws, cases and relevant references, which are analyzed to obtain conclusions and recommendations. Research shows that the court considered using the Comparable Profits Method by tax authorities to evaluate the profitability of The Coca-Cola Company's supply points, given the difficulty of valuing int

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DUDLEY, GEOFFREY. "THE NEXT STEPS AGENCIES, POLITICAL SALIENCE AND THE ARM'S-LENGTH PRINCIPLE: BARBARA CASTLE AT THE MINISTRY OF TRANSPORT 1965-68." Public Administration 72, no. 2 (1994): 219–40. http://dx.doi.org/10.1111/j.1467-9299.1994.tb01009.x.

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Stradinger, Theresa. "Classification of Cost Allocation Agreements." Intertax 41, Issue 12 (2013): 665–75. http://dx.doi.org/10.54648/taxi2013064.

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Cost Allocation Agreements have begun to play an important role for MNEs in order to make intellectual property available to foreign subsidiaries. Cost Allocation Arrangements based on the pool-concept are a form of allocation financing. In the international context, different wordings for Cost Allocation Agreements (e.g., Cost Sharing Arrangements) are used. This paper is concerned with Cost Allocation Agreements in the area of R&D, which are based on the pool-concept. Cost Allocation Agreements are not based on specific national or international legal basis, but are the result of nationa

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Aisya, Saraswati, and Siti Nuryanah. "Tax Dispute Analysis of Transfer Pricing Case Study of Tax Court Decisions 2020-2023." JMKSP (Jurnal Manajemen, Kepemimpinan, dan Supervisi Pendidikan) 9, no. 1 (2024): 481–95. http://dx.doi.org/10.31851/jmksp.v9i1.14343.

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Tax Disputes of Transfer Pricing still become the most popular tax issue and the challenge for the MNEs' establishment worldwide. Furthermore, this study aims to continue previous research by conducting content analysis on tax court appeal decisions issued in 2020-2023. This content analysis aims to determine taxpayers' business characteristics as an essential indicator for applying the arm's length principle based on the tax court decisions for 2020-2023. The results of this study show that each type of affiliate transaction that experiences a transfer pricing tax dispute has different charac

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Nurhasanah, Ayu, Purwanti Purwanti, and Wati Della Puspita. "Pengaruh Transfer Pricing Perusahaan Induk dan Cabang Skala Multinasional pada PT Toyota Motor Manufacturing Indonesia." Jurnal Ilmiah Manajemen, Bisnis dan Kewirausahaan 5, no. 2 (2025): 280–92. https://doi.org/10.55606/jurimbik.v5i2.1101.

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The purpose of this study is to analyze the transfer pricing practices carried out by PT Toyota Motor Manufacturing Indonesia (TMMIN), a subsidiary of Toyota Motor Corporation Japan, and its impact on tax obligations in Indonesia. The method used is a qualitative descriptive approach through case studies, through data collection techniques with literature studies and documentation. The results of the study indicate that TMMIN is involved in affiliate transactions that are not in accordance with the arm's length principle, such as sales at prices below market and the imposition of royalties tha

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