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Journal articles on the topic 'Conceptual principles of transfer pricing'

Author: Grafiati

Published: 28 May 2022

Last updated: 31 July 2025

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1

Kvasovskyi, Oleksandr, and Vitaliy Rudan. "Theoretical-conceptual and scientific-applied dominants of transfer pricing policy for economic entities." Economic Analysis, no. 34(1) (2024): 165–78. http://dx.doi.org/10.35774/econa2024.01.165.

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Introduction. Through the adept use of transfer pricing, companies can optimize their costs, minimize various types of risks, maximize profits, and gain tangible competitive advantages. At the same time, in the context of increased fiscal control and constant changes in the international tax environment, adherence to fiscal-regulatory requirements regarding transfer pricing by economic entities gains special importance. Therefore, companies need to develop, implement, and continuously modernize their own corporate transfer pricing policy, as it not only contributes to overall financial success

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2

Brem, Markus, and Thomas Tucha. "Transfer Pricing: Conceptual Thoughts on the Nature of the Multinational Firm." Vikalpa: The Journal for Decision Makers 31, no. 2 (2006): 29–44. http://dx.doi.org/10.1177/0256090920060202.

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This paper deploys Transaction Cost Economics (TCE) to elaborate on the shortcomings of ‘mainstream‘ transfer pricing in multinational firms. Departing from the notion that multinationals increasingly (re-)organize their business along multinational value chains irrespective of jurisdictional borders, this paper discusses the nature of the multinational firm and the problem of choosing the right intra-group (transfer) price. The mainstream transfer pricing approach derived from the Arm�s Length Principle (ALP) is deemed inappropriate for globally operating multinational enterprises (MNEs). Ref

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Jakfar and Fariha Nuraini. "Transfer Pricing and Tax Avoidance: A Narrative Review of Global Strategies and Regulatory Challenges." Sinergi International Journal of Economics 3, no. 2 (2025): 97–107. https://doi.org/10.61194/economics.v3i2.645.

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This narrative review investigates how transfer pricing is strategically utilized by multinational enterprises to facilitate international tax avoidance. The study aims to assess the role of pricing arrangements between related entities in shifting profits to low-tax jurisdictions. Using a comprehensive narrative methodology, literature was gathered from databases such as Scopus and Google Scholar, applying specific keywords and inclusion criteria to identify relevant empirical and conceptual studies. The review identifies a pattern of aggressive transfer pricing behavior, particularly in indu

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Oguttu, Annet Wanyana. "Challenges of Applying the Comparability Analysis in Curtailing Transfer Pricing: Evaluating the Suitability of Some Alternative Approaches in Africa." Intertax 48, Issue 1 (2020): 74–102. http://dx.doi.org/10.54648/taxi2020006.

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This article asserts that transfer pricing is perhaps the greatest profit shifting problem facing the international tax system. Thus, countries have historically been keen on preventing transfer pricing and on finding effective and efficient methods for allocating revenue that are administratively cost effective for both taxpayers and tax administrators. However, the problem as articulated in this article is that the comparability analysis that underpins the application of the arm’s length principle (ALP) which is applied internationally to curb transfer pricing, continues to be a vexing probl

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Mwape, Victor, Austin Mwange, and Munyonzwe Hamalengwa. "Reassessing the Arm’s Length Principle in Transfer Pricing Regulation: A Doctrinal and Practical Analysis from a Zambian Perspective." African Journal of Commercial Studies 6, no. 1 (2025): 199–206. https://doi.org/10.59413/ajocs/v6.i.1.18.

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The arm’s length principle (ALP) has long been considered the cornerstone of international transfer pricing regimes. Originating from Article 9 of the OECD Model Tax Convention, the ALP aims to ensure that transactions between related entities reflect market conditions as if undertaken by independent enterprises. This article critically examines the doctrinal, institutional, and practical dimensions of the ALP, particularly within the context of developing economies such as Zambia. While the ALP underpins Zambia’s transfer pricing regulatory framework, significant concerns remain regarding its

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Jain, Ajit Kumar. "When Machines Create Value: Rethinking Transfer Pricing for AI-Driven Economies." International Journal for Research in Applied Science and Engineering Technology 13, no. 7 (2025): 1567–81. https://doi.org/10.22214/ijraset.2025.73236.

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Artificial Intelligence (AI) is transforming how multinational enterprises (MNEs) generate, manage, and capture value—posing unprecedented challenges for international transfer pricing frameworks rooted in traditional human-performed functions and tangible asset ownership. This paper explores the disruptive implications of AI-driven business models for the arm’s length principle, focusing on decentralized decision-making, data-based intangibles, and algorithmic value creation. By analyzing use cases across industries such as financial services, pharmaceuticals, and e-commerce, the study highli

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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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Solange Screpante, Mirna. "The Arm’s Length Principle Evolves Towards a ‘Value Creation Functional (i.e. DEMPE) Formula Standard’: A Barrier or a Gateway to Locational Business Planning?" Intertax 48, Issue 10 (2020): 861–78. http://dx.doi.org/10.54648/taxi2020087.

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Value creation vis-à-vis the DEMPE rationale and methodology converted a conceptual notion associated with contributions to value creation but lacking prescription into a new standard to allocate profits to achieve reunification for tax purposes in a manner consistent with the directions of the arm’s length principle (ALP). Within this context, this article questions whether value creation could or should be based on a functional (i.e. DEMPE)-formula-based standard to allocate profits, and whether such an approach would target or abet tax avoidance framed by apparently genuine structures –‘acc

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Khvesyk, Mykhailo A., Oleksandr M. Shubalyi, Julia M. Khvesyk, and Natalia M. Vasilik. "Conceptual basis of transformation of ecological and economic relations in the forest sector of Ukraine in the context of European integration." Folia Forestalia Polonica 61, no. 2 (2019): 97–111. http://dx.doi.org/10.2478/ffp-2019-0010.

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Abstract The article defines the priorities, principles and main provisions of national forest policy of Ukraine towards European integration. The main objectives and structure of the mechanism of transformation of ecological and economic relations in the forest sector of Ukraine is grounded. The main tasks of transformation of ecological and economic relations in the forest sector should be decentralization of the management system, budget savings and sustainability, sustainable development and ecological security, development of public and private partnership, and welfare of local communitie

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Pogorelova, Lioubov. "Transfer-Pricing and Game Theory." Intertax 43, Issue 5 (2015): 395–404. http://dx.doi.org/10.54648/taxi2015034.

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This article examines the complex nature of the transfer-pricing problem to determine how strategic considerations of organizations guide the application of different types of game-theoretic models for a profit-split transfer-pricing method. The article proposes a conceptual framework that links strategy with specific game-theoretic models in transfer-pricing decision-making.

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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

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Pogorelova, Lioubov. "Trade and Transfer Pricing." Intertax 40, Issue 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 poin

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CHUKURNA, Оlena, Liudmyla HALAN, and Nataliia KALUHINA. "THEORETICAL AND METHODOLOGICAL PRINCIPLES OF TRANSFER PRICING POLICY IN THE MARKETING SYSTEM IN THE CONDITIONS OF GLOBALIZATION." Development Service Industry Management, no. 2 (May 15, 2025): 280–87. https://doi.org/10.31891/dsim-2025-10(37).

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The main purpose of the article is to study the evolution of theoretical and methodological approaches to transfer pricing in the context of marketing. In the context of constant economic transformation and technological changes, pricing processes are also undergoing changes under the influence of a number of economic, in particular globalization, factors. Therefore, there is a need for a comprehensive scientific analysis of changes in approaches to transfer pricing and in determining the globalization influences that shape its modern foundations. The research methodology is based on a combina

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Oestreicher, Andreas. "German Transfer Pricing Principles – An Old Theme Revisited." Intertax 32, Issue 3 (2004): 137–47. http://dx.doi.org/10.54648/taxi2004021.

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Kartikaningdyah, Ely, Eko Ganis Sukoharsono, Lilik Purwanti, and Roekhudin Roekhudin. "Synergy of Pancasila ethical principles and transfer pricing practices for economic sustainability." International Journal of Innovative Research and Scientific Studies 8, no. 3 (2025): 463–73. https://doi.org/10.53894/ijirss.v8i3.6549.

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This study attempts to reconstruct the ethical principles of Pancasila with fair transfer pricing practices to create a set of guidelines that encourage economic sustainability in Indonesia, using a qualitative-critical approach. Data were obtained through in-depth interviews with tax authorities, tax consultants, and multinational companies, as well as document analysis using thematic techniques and NVivo 12 software. Findings suggest that although transfer pricing is legally permitted, the practice is often manipulated to suppress tax burdens, thereby reducing state revenues and exacerbating

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Rudaia, M. "TRANSFORMATION PRISING INNOVATIONS IN OFFSHORE OPERATIONS." Criminalistics and Forensics, no. 64 (May 7, 2019): 699–707. http://dx.doi.org/10.33994/kndise.2019.64.66.

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The article deals with modern approaches to the issue of transfer pricing in the conditions in offshore operations. Considerable attention is spared to the innovations in a tax law on counteraction to washing out of tax base and leadingout of acuestss from taxation. The modern characteristic features of intercommunication of offshore financial jurisdictions and renewed three-level format of accounting are certain on the transfer pricing. Therefore considerable actuality is acquired by possibilities to carry out control a supervisory organ after the transfer pricing, a duty is set for taxpayers

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17

Capatina-Verdes, Neli. "Transfer Pricing and Related Party Transactions: A Bibliometric Analysis." Central European Economic Journal 9, no. 56 (2022): 237–53. http://dx.doi.org/10.2478/ceej-2022-0014.

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Abstract In order to create complex business structures and to obtain economic benefits, multinational companies have given rise to transfer pricing. Due to their importance, it has been possible to expand international trade to a higher level. This study focuses on the issue of transfer pricing and related party transactions (RPT), with the aim to overview the productivity and impact of research in transfer pricing and RPT area highlighting the main research trends in the field. 3885 papers extracted in February 2022 from Web of Science and Scopus databases were examined and basic topics deba

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18

Alekhnovich, Nikita I. "APPLYING OF TRANSFER PRICING TAX CONTROL INTERNATIONAL EXPERIENCE IN RUSSIA IN CONDITIONS OF MODERN ECONOMY." EKONOMIKA I UPRAVLENIE: PROBLEMY, RESHENIYA 4/1, no. 157 (2025): 58–65. https://doi.org/10.36871/ek.up.p.r.2025.04.01.007.

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The author describes the main methods of tax control of transfer pricing, which are used in Russia and in the world. He also analyzes the international experience of applying these methods and evaluates the possibility of implementing individual principles of transfer pricing tax control international practice in the conditions of Russian tax legislation.

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19

KALOVA, DAGMAR. "CONCEPTUAL FRAMEWORK FOR DETERMINING THE TRANSFER PRICE OF THE LOANS." AD ALTA: 13/01 13, no. 1 (2023): 140–45. http://dx.doi.org/10.33543/j.1301.140145.

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Associated enterprises integrated into business groups may use the capital resources of the group. When setting the remuneration for their use, they must ensure that prices between them are set according to the rules of the Organisation for Economic Co-operation and Development (OECD). The core document is the Transfer Pricing Guidance on Financial Transactions. Based on the results of a qualitative analysis (content and contextual analysis of the document), the aim of the article is to systematize the procedures used to determine the transfer price in financial transactions such as loans and

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20

Niu, Yunhe. "Regulatory Issues and Recommendations on Transfer Pricing Tax Avoidance by Multinational Corporations." Highlights in Business, Economics and Management 16 (August 2, 2023): 401–6. http://dx.doi.org/10.54097/hbem.v16i.10606.

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In recent years, with the continuous development of the global economy, multinational corporations allocate resources in various ways to reduce the overall tax burden of the group to achieve the business goal of profit maximization. The transfer pricing method is one of the most common international tax avoidances means used by multinational corporations. Although transfer pricing tax avoidance does not constitute an illegal act in form, in substance, it causes serious capital loss in the host country and infringes on the tax sovereignty of the host country. However, there are still many resea

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21

Grinenko, Julia, Dmytro Melnychuk, Larysa Mykhalchyshyna, Svitlana Belei, and Nataliia Yevtushenko. "Improving transfer pricing in Ukraine using American Experience." Independent Journal of Management & Production 12, no. 3 (2021): s205—s231. http://dx.doi.org/10.14807/ijmp.v12i3.1524.

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The purpose of the present research is to determine the characteristics of transfer pricing and proposals for its improvement, identifying key factors applying transfer pricing and the development of organizational and economic measures for the implementation of the mechanism of transfer pricing in Ukrainian enterprises based on US experience. Due to significant growth of the number of multinationals since 1950, and expanding the geographical environment of their activities caused the increase in the number of studies on transfer pricing. Strengthening external instability greatly affected the

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22

Solilová, Veronika. "Revised OECD Transfer pricing Guidelines and the Czech tax policy." Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis 59, no. 4 (2011): 301–8. http://dx.doi.org/10.11118/actaun201159040301.

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In applying the international principles to the taxation of Multinational Enterprises, one of the most difficult issues that have arisen is the establishment for tax purposes of appropriate transfer prices. Transfer prices are significant for both taxpayers and tax administrations because they determine in large part the income and expenses, and therefore taxable profits, of associated enterprises in different tax jurisdictions. The Committee on Fiscal Affairs, which is the main tax policy body of the OECD, has issued a number of reports relating to the transfer pricing issues. The most import

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23

Jaworski, Piotr, Kamil Liberadzki, and Marcin Liberadzki. "Principles of the toll roads pricing." Archives of Transport 45, no. 1 (2018): 43–52. http://dx.doi.org/10.5604/01.3001.0012.0941.

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In this paper the authors refer to the method of commercial provision of road infrastructure called BOT (build-operate-transfer) under Public-private partnerships (PPPs) scheme. First we present the investment criteria for transportation PPP projects as well as application of price theory. Then we recognize that the different participants in PPP projects have distinct goals and requirements that must be met in order for them to be able to participate in an effective partnership. The main challenge for the toll road pricing is to determine the economically viable toll rate that takes into consi

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KURILOV, YEVHEN. "INTERNATIONAL EXPERIENCE IN PROCESSING AND ASSESSMENT BY REGULATORY AUTHORITIES OF TRANSFER PRICING RISKS." HERALD OF KHMELNYTSKYI NATIONAL UNIVERSITY 296, no. 4 (2021): 156–62. http://dx.doi.org/10.31891/2307-5740-2021-296-4-25.

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The article analyzes and summarizes the international experience of regulatory authorities in dealing with transfer pricing risks as one of the basic elements of tax control over taxpayers’ compliance with transfer pricing rules. An efficient process for processing and assessing transfer pricing risks helps to ensure quality selection and increase the effectiveness of audits of controlled transactions, increase the efficiency of the use of limited resources, as well as greater tax certainty and reduce the number of unreasonable audits. As a result of the study: international experience was sum

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Komarudin, Mamay, Hari Gursida, and Yohanes Indrayono. "Indonesian Case: Good Corporate Governance, Company Size, Taxes, and Transfer Pricing." Journal of Business and Management Review 3, no. 12 (2022): 826–40. http://dx.doi.org/10.47153/jbmr311.5022022.

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ge companies have tax deficiencies and will inevitably use more aggressive transfer pricing manipulations. GCG and company size can influence company decisions in making transfer pricing. This research is fundamental to developing a model and conceptual coding and causality of transfer pricing practices while testing the influence of motivational factors on transfer pricing. The problem in this study is that Good Corporate Governance (GCG) strengthens the effect of taxes on transfer pricing in multinational companies, and apakah of company size weakens the influence of taxes on transfer pricin

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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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Dewi, Renita Rachma, and Elia Mustikasari. "Analisis Penanganan Manipulasi Transfer Pricing Perpajakan Dalam Menjawab Tantangan Global." E-Jurnal Akuntansi 30, no. 2 (2020): 460. http://dx.doi.org/10.24843/eja.2020.v30.i02.p14.

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Transfer pricing basically aims to measure company performance and has become a media to manipulate taxes, resulting in state revenue, which results in state stability, national problems and global challenges. This research method is qualitative with the transfer pricing case study approach. The data is secondary and the process of collecting data from reliable online sources. The analysis technique uses data reduction, data display and verification. The results explain that the factors of manipulation of transfer pricing are the presence of special company relationships, bonus systems and mec

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Arrisman, Arrisman, and Ahmad Fauzi. "Analisis Yuridis Pembuktian Sengketa Transfer Pricing." Syntax Literate ; Jurnal Ilmiah Indonesia 10, no. 2 (2025): 2179–91. https://doi.org/10.36418/syntax-literate.v10i2.56912.

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This research is about the juridical analysis of the proof of transfer pricing disputes with an example of the case of the Tax Court decision No.Put.74576/PP/M.IB/15/2016. The ruling granted an appeal filed by PT HI, a foreign investment company from Japan. Transfer Pricing or TP occurs in transactions involving "Taxpayers with parties who have a special relationship" (affiliates) based on Article 18 of the Income Tax Law. Taxpayers with affiliated transactions are required to fill in the information and method of testing TP on the Corporate Income Tax Return based on TP documentation. In the

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Skrypnyk, Olha. "CONCEPTUAL PRINCIPLES OF PRICING IN THE AERATED CONCRETE MARKET IN UKRAINE IN THE CONTEXT OF ECONOMIC CYCLICALITY." Three Seas Economic Journal 1, no. 4 (2020): 139–45. http://dx.doi.org/10.30525/2661-5150/2020-4-20.

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The purpose of the paper is to identify patterns of influence of macroeconomic and sectoral factors on the dynamics of prices of aerated concrete products during 2015-2020. The method of factor analysis was used to identify the degree of influence of a number of macroeconomic indicators and raw material prices on the pricing of aerated concrete products. Using the graphical method, the patterns of change in the growth rate of aerated concrete prices at different phases of the economic cycle during this period were identified. Methodology. The study is based on the identification of correlation

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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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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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Mandal, Pratap Chandra. "Pricing and Ethical Issues for Global Markets." International Journal of Business Strategy and Automation 2, no. 2 (2021): 1–15. http://dx.doi.org/10.4018/ijbsa.20210401.oa1.

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Multinationals operating in global markets require analyzing several pricing considerations. They require setting appropriate prices of their products for each of the markets they operate in. Price of a product is an important criterion which decides whether a product will get sold or not. Companies contend with a number of issues in pricing like geographical pricing, price escalation, transfer prices, dumping charges, pricing for emerging markets, and pricing for individuals at the bottom of the pyramid. There are several legal and ethical aspects in pricing. These include deceptive or illega

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Хаванова, Инна, and Inna Khavanova. "Category of Market Price in Modern Tax Law." Journal of Russian Law 4, no. 7 (2016): 0. http://dx.doi.org/10.12737/20152.

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 The article is devoted to transfer pricing rules with particular reference to unresolved problems. Its purpose is to outline the complex issue of transfer pricing. The author examines the difference between the concepts of “market price” and price, determined according to the “arm’s length principle”, discusses the basic rules of taxation, principles of determining the price of goods, work or services for taxation purposes. To ensure the correct application of the separate entity approach, countries have adopted the arm&#180;s length principle. This article analyzes initiatives on t

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Muzychuk, Mariana. "INTERNATIONAL TAXATION SYSTEM TRANSFORMATION: ITS EFFECT ON TRANSFER PRICING (TP)." BULLETIN OF CHERNIVTSI INSTITUTE OF TRADE AND ECONOMICS IV, no. 84 (2021): 81–95. http://dx.doi.org/10.34025/2310-8185-2021-4.84.06.

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In the context of globalization of the world economy and the growth of its digital segment, there is a need to revise the basic principles applied in the international tax system. Inequality of tax approaches in different countries creates tax competition between them and allows multinationals to shift their profits to jurisdictions with low tax rates. The supply of digital services under the current rules has not been taxed in the countries of their consumption and attempts to regulate their taxation by individual countries lead to trade wars. The OECD / G20 initiative envisages the introduct

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Yanurwenda, Benny Oktis, and Rindah Febriana Suryawati. "Review of Taxation Aspect of Cash Poolings Based on Indonesian Regulations." Scientax 6, no. 2 (2025): 124–34. https://doi.org/10.52869/st.v6i2.529.

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Cash poolings are typically formed by companies in a single business group. Therefore, most of the transactions are affiliated transactions that must meet the Arm’s Length Principles. This study reviews the implementation of the Arm’s Length Principles in cash poolings. This research utilized a qualitative approach by reviewing elements of cash pooling transactions with Indonesia’s regulations and best practices in transfer pricing. The study concluded that implementing transfer pricing regulations in cash pooling arrangements would depend on the role of the leader. Based on the role of the le

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Smolarski, Jan M., Neil Wilner, and Jose G. Vega. "Dynamic transfer pricing under conditions of uncertainty – the use of real options." Journal of Accounting & Organizational Change 15, no. 4 (2019): 535–56. http://dx.doi.org/10.1108/jaoc-08-2018-0083.

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Purpose This paper aims to examine the applicability of real options methodology with respect to developing internal transfer pricing mechanisms. A pervasive theme in existing models is their inability to handle the dynamic and volatile nature of today’s business environment, as well as their lack of objective managerial flexibility. The authors address these and other issues and develop a transfer pricing mechanism based on Black–Scholes and the binomial options pricing methodology, which is better suited in today’s dynamic business environment. Design/methodology/approach The authors use a c

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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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Bezuglіy, Artem, Ihor Hresko, and Yuliya Bibyk. "Conceptual principles for determining the cost of project works for road works and services in the context of international experience." Dorogi i mosti 2024, no. 30 (2024): 25–39. http://dx.doi.org/10.36100/dorogimosti2024.30.025.

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ntroduction. The road sector is one of the industries governed by a large number of laws, regulations, and other normative-legal acts, many of which directly or indirectly affect it. Some of these require adaptation to the current conditions of the modern market and integration with the ongoing processes in the industry. Implementing new or amending existing normative-legal acts and regulatory documents is usually a complex process. Currently, Ukraine's economy is in a transitional period, largely due to military actions on its territory. Thus, addressing issues related to determining the cost

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Ištok, Michal, Veronika Solilová, and Karel Brychta. "Challenges in transfer pricing: A concept of safe harbours for financial transactions." Financial Internet Quarterly 18, no. 4 (2022): 23–34. http://dx.doi.org/10.2478/fiqf-2022-0025.

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Abstract The OECD project against BEPS has brought and initiated many changes – among others, in the OECD Transfer Pricing Guidelines. To react and respond to changes in the current business environment, a new chapter for transfer pricing in financial transactions has also been introduced (namely chapter X). This step can be considered beneficial. However, meeting all the requirements for setting a transfer price for financial transactions seems to remain a very demanding and expensive task. Furthermore, the OECD Transfer Pricing Guidelines have been of a general nature rather than providing r

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Putri, Vidiyanna Rizal, Mohd Hadli Shah Mohamad Yunus, Nor Balkish Zakaria, Meliza Putriyanti Zifi, Istianingsih Sastrodiharjo, and Rosiyana Dewi. "Tax Avoidance with Maqasid Syariah: Empirical Insights on Derivatives, Debt Shifting, Transfer Pricing, and Financial Distress." Journal of Risk and Financial Management 17, no. 11 (2024): 519. http://dx.doi.org/10.3390/jrfm17110519.

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This study analyzes and investigates how financial factors, namely, derivatives, debt shifting, and transfer pricing, influence tax avoidance, with financial distress as an interaction variable, within the framework of stakeholder theory and positive accounting theory. Adding more uniqueness, this study injected the Maqasid Syariah elements into the framework. Conventional banks and non-bank institutions listed on the Indonesia Stock Exchange (IDX) between 2017 and 2022 were selected, comprising 414 final company-year observations. The study utilized E-Views software for data processing. The f

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Olika, Daniel. "Transfer Pricing Documentation Methods in Nigeria: A Critique of the Prime Plastichem Case Against International Best Practices." African Journal of International and Comparative Law 32, no. 1 (2024): 149–62. http://dx.doi.org/10.3366/ajicl.2024.0478.

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The quest to ensure that the tax planning activities of multinational enterprises operating in Nigeria do not erode the country's domestic tax base has led to the enactment and enforcement of the Transfer Pricing (TP) Regulations, 2018 in Nigeria. The TP Regulation provides for a comprehensive framework to ensure that the pricing of related party transactions is consistent with global best practices on TP. The enforcement of the TP Regulation in Nigeria was taken a step further in 2020 when the Tax Appeal Tribunal affirmed the imposition by the Federal Inland Revenue Service (FIRS) of liabilit

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Banovec, P., and P. Domadenik. "Paying too much or too little? Pricing approaches in the case of cross-border water supply." Water Supply 18, no. 2 (2017): 577–85. http://dx.doi.org/10.2166/ws.2017.126.

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Abstract Cross-border drinking water supply is often a solution for the emerging water crisis, related also to climate changes, but in several cases also a historical legacy of changing borders. It is challenged by the increased complexity of water supply management, mainly because of the doubled reality of administrative, legal, accounting and decision-making processes. Analyzed water pricing of existing cross-border utilities clearly demonstrates applied water pricing approaches mainly based on pure negotiation principles demonstrating different and often heavily asymmetric bargaining positi

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Fulop, Renata. "The influence of fiscal regulations on transfer pricing: a bibliometric review." Virgil Madgearu Review of Economic Studies and Research 15, no. 1 (2022): 35–57. http://dx.doi.org/10.24193/rvm.2022.15.84.

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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. The potential use of international transfer pricing as an income shift by multinational enterprises has long been recognized. Many tax-related scandals have been made public in the past few years involving some of the major multinational enterprises at this time. These were accused of practicing tax avoidance on an industrial scale b

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Kvasovskyi, Oleksandr, Mykola Stetsko, and Olga Nipialidi. "Tax risks of business entities in the field of transfer pricing and ways to prevent and minimise them." Herald of Economics, no. 1 (May 3, 2024): 47–66. http://dx.doi.org/10.35774/visnyk2024.01.047.

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Introduction. The introduction of the transfer pricing fiscal regulation system in Ukraine restricts business entities to use it for tax minimisation purposes, which leads to a reduction in fiscal revenues, outflow of profits to low-tax jurisdictions, distortion of competition and a general slowdown in macroeconomic development. At the same time, compliance with complex tax and regulatory procedures for transfer pricing negatively affects the financial performance of companies and hinders their development. The dilemma of finding compromise solutions that balance the fiscal interests of the st

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Elumilade, Oluwafunmike O., Ibidapo Abiodun Ogundeji, Godwin Ozoemenam Achumie, Hope Ehiaghe Omokhoa, and Bamidele Michael Omowole. "Optimizing corporate tax strategies and transfer pricing policies to improve financial efficiency and compliance." Journal of Advance Multidisciplinary Research 1, no. 2 (2022): 28–38. https://doi.org/10.54660/.jhmr.2022.1.2.28-38.

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in an increasingly globalized economy, multinational corporations (MNCs) face complex challenges in optimizing corporate tax strategies and transfer pricing policies to enhance financial efficiency while ensuring compliance with evolving regulatory frameworks. Effective tax planning is essential for minimizing tax liabilities, improving cash flow, and maintaining competitiveness. Transfer pricing, which governs intra-group transactions, plays a crucial role in determining taxable profits across different jurisdictions. However, improper transfer pricing practices can lead to regulatory scrutin

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Nazwari, Fadia, Madnasir Madnasir, and Suhendar Suhendar. "The Influence of Tax Minimization, Debt Covenant, and Exchange Rate on Transfer Pricing in an Islamic Economic Perspective: Study on Transportation and Logistics Companies Listed on the Indonesia Stock Exchange 2021-2023." Jurnal Ilmiah Mizani: Wacana Hukum, Ekonomi Dan Keagamaan 12, no. 1 (2025): 241. https://doi.org/10.29300/mzn.v12i1.7350.

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This study examines the influence of tax minimization, debt covenants, and exchange rates on transfer pricing practices among transportation and logistics companies listed on the Indonesia Stock Exchange from 2021 to 2023. Adopting a quantitative approach, the research employs secondary panel data collected from corporate financial reports and the official IDX database. A purposive sampling method was used to select 14 firms, resulting in 42 firm-year observations. Data analysis was conducted using multiple linear regression with MS Excel and IBM SPSS 30. The results show that, individually, t

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Kraievskyi, Volodymyr, and Serhii Polishchuk. "TRANSFORMATION OF TRANSFER PRICING POLICY IN THE CONTEXT OF ESG-ORIENTED BUSINESS STRATEGIES." Економіка розвитку систем 7, no. 1 (2025): 42–49. https://doi.org/10.32782/2707-8019/2025-1-6.

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The article examines the transformation of transfer pricing policy in the context of modern challenges in the global economy, particularly the integration of ESG-oriented business strategies. The authors demonstrate that the integration of environmental, social, and governance (ESG) aspects into corporate governance systems is reshaping approaches to transfer pricing analysis, driven by the need to harmonise the financial interests of businesses with sustainable development goals. The article goes on to provide a comprehensive overview of the theoretical underpinnings of ESG metrics, which are

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Bormotova, Alexandra, Nadežda Glubokova, Anna Agapova, Ivan Alyshev, Elizaveta Larkova, and Daria Lomakina. "Aspects of application of tax control by countries for cross-border operations." International Review, no. 3-4 (2021): 188–200. http://dx.doi.org/10.5937/intrev2103186b.

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International taxation, as follows from the theory, is a study of the tax burden on individuals or legal entities in accordance with the tax laws of different countries or international law. Russia, the United States and the EU are global jurisdictions with the most complete tax legislation concerning transfer pricing. In this regard, it is very useful to consider the experience of countries with different principles of taxation of international transactions, which will undoubtedly contribute to improving tax control over international transactions. As a rule, when performing cross-border tran

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Widjaja, Gunawan, Miftahul Arifin, Prasetyono Hendriarto, Muhamad Stiadi, and M. Zahari MS. "Identification of transfer pricing practices in the era of multinational company competition." Linguistics and Culture Review 5, S2 (2021): 1460–70. http://dx.doi.org/10.21744/lingcure.v5ns2.1975.

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This study presents the results of identifying practical transfer pricing among multinational companies operating in an era full of global competition. The study is to gain an understanding and experience of practical transfer pricing among foreign companies operating in Indonesia. Our data search was conducted on international publications. After getting the data, our in-depth data analysis efforts involve a data evaluation system, data interpretation, and coding so that the data we produce answers the study questions with the highest principles. We report this study is a descriptive qualitat

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KOROL, Svitlana, and Olha ROMASHKO. "Corporate social responsibility in transfer pricing strategies." Foreign trade: economics, finance, law 122, no. 3 (2022): 4–18. http://dx.doi.org/10.31617/zt.knute.2022(122)01.

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Introduction. International groups of companies (IGCs) have significant economic, environmental, and social impacts on the region of presence. The most powerful mechanism for influencing regional development is IGC payments to the state. Problem. The object of the study was selected by IGC, which did business in Russia in early 2022. The aim of the article is to analyze the transfer pricing strategy of the IGCs in the context of their implementation of the principles of corporate social responsibility, achieving the Sustainable Development Goals (SDGs) and, in particular, promoting peace

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