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Journal articles on the topic 'TP (Transfer Pricing)'

Author: Grafiati

Published: 5 June 2025

Last updated: 2 August 2025

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1

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 pro

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Apriyanti, Hani Werdi, Suzana Sulaiman, and Adibah Jamaluddin. "Transfer pricing optimization in the developing economy: A tax consultant’s view." Corporate Governance and Organizational Behavior Review 7, no. 2 (2023): 190–96. http://dx.doi.org/10.22495/cgobrv7i2p17.

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Transfer pricing (TP) is usually used by multinational companies (MNCs) to minimize corporate tax liabilities, using affiliates. This practice involves tax consultants optimizing transfer pricing without violating the tax regulation. Tax consultants contribute to supervising companies to make transparent documentation and transfer pricing policies. This qualitative research explores the tax consultant perspective on companies’ transfer pricing optimization behaviour using planned behaviour theory. Data was collected through interviews, documentation, and observations. This research involves 5

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Sukarno, Supriyadi. "Apakah Transfer Pricing Documentation Meningkatkan Kepatuhan Pajak?" Jurnal Pajak dan Keuangan Negara (PKN) 4, no. 1S (2022): 245–52. http://dx.doi.org/10.31092/jpkn.v4i1s.1864.

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OECD menerbitkan OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 untuk menjadi pedoman dalam penerapan Transfer Pricing bagi perusahaan multinasional dan otoritas perpajakan. Penelitian ini bertujuan untuk mengidentifikasi dan menganalisis ketentuan kewajiban Transfer Pricing Documentation (TP Doc) dalam rangka meningkatkan kepatuhan pajak menurut Undang-undang Harmonisasi Peraturan (UU HPP) Nomor 7 Tahun 2021. Metode penelitian yang digunakan adalah pendekatan kualitatif dengan analisis literatur review dari hasil penelitian dan peraturan perpajakan

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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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Al-Hamadeen, Radhi, Taha Almarayeh, Dana Fakhoury, Jowan Rezqallah, Nadeen Zraiqat, and Zein Marzouka. "Transfer pricing applicability: Perceptions of the tax professionals." Corporate Governance and Organizational Behavior Review 7, no. 1 (2023): 166–77. http://dx.doi.org/10.22495/cgobrv7i1p16.

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Recently, transfer pricing (TP) regulation was introduced in Jordan for the first time in the country’s history (Income and Sales Tax Department [ISTD], 2021). This research evaluates the overall awareness of tax professionals on TP and its applicability in the early stage of its implementation. This is mainstream accounting research that adopts the quantitative research approach to collect data. In this context, a research questionnaire consisting of 29 items was designed and distributed to TP specialists to investigate four key aspects of TP applicability and impact. The results of the study

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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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Dwi Saputra, Anggari. "UNRAVELING THE EFFECTS OF TRANSFER PRICING DOCUMENTATION REGULATION: INDONESIA’ EVIDENCE." Jurnal Akuntansi dan Keuangan Indonesia 20, no. 2 (2023): 186–205. http://dx.doi.org/10.21002/jaki.2023.10.

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To counter tax avoidance using transfer mispricing practices, Indonesia introduced a transfer pricing documentation policy. This policy requires taxpayers to be transparent with their transfer pricing decisions. Treating the implementation of this policy as a shock to the taxpayers, this paper examines how the transfer pricing documentation policy affects a firm's tax avoidance behaviour by employing regression discontinuity design and difference-in-difference. Immediately after introducing the policy, a regression discontinuity analysis results indicate a 0.9 percentage point increase in tax/

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Amidu, Mohammed, William Coffie, and Philomina Acquah. "Transfer pricing, earnings management and tax avoidance of firms in Ghana." Journal of Financial Crime 26, no. 1 (2019): 235–59. http://dx.doi.org/10.1108/jfc-10-2017-0091.

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Purpose This paper aims to investigate how transfer pricing (TP) and earnings management affect tax avoidance of firms in Ghana. Design/methodology/approach The authors use a panel data set from 2008 to 2015 to further shed light on transfer pricing-tax avoidance nexus by examining the complex interaction of three key variables: transfer pricing, earnings management and tax avoidance. Findings The results show that almost all the sample firms have engaged in some form of transfer pricing strategies and the manipulation of earnings to avoid tax during 2008-2015. There is evidence to suggest tha

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Dharmawan, Nyoman Ari Surya, Komang Adi Kurniawan Saputra, and I. Gede Arya Wigarba. "The Moderating Role of Corporate Governance in the Relationship Between Transfer Pricing and Tax Avoidance." Jurnal Ilmiah Akuntansi dan Bisnis 19, no. 2 (2025): 293. https://doi.org/10.24843/jiab.2024.v19.i02.p07.

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This study investigates the relationship between transfer pricing (TP) and tax avoidance (TA), with corporate governance (CG) serving as a moderating variable. The research focuses on manufacturing firms listed on the Indonesia Stock Exchange (IDX) from 2017 to 2022. The sample comprises 180 observations derived from 30 multinational manufacturing companies, selected through a purposive sampling technique based on specific criteria. Panel data regression analysis was employed, utilizing models both with and without the moderating variable. The findings indicate that TP positively influences TA

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Cools, Martine, and Regine Slagmulder. "Tax-Compliant Transfer Pricing and Responsibility Accounting." Journal of Management Accounting Research 21, no. 1 (2009): 151–78. http://dx.doi.org/10.2308/jmar.2009.21.1.151.

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ABSTRACT: While the accounting literature has extensively studied the role of transfer pricing (TP) within the management control system (MCS) of companies, MCS issues related to cross-border transfers have received far less attention. In this case study, we investigate how TP tax compliance influences responsibility accounting when one multinational enterprise (MNE) uses a single set of transfer prices for both tax compliance and management control. First, the MNE eliminated TP negotiation, leading to psychologically disagreeable and sometimes also economically harmful situations. Second, the

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MUZYCHUK, Mariana. "ACCOUNTING OF CONTROLLED TRANSACTIONS." Herald of Kyiv National University of Trade and Economics 143, no. 3 (2022): 126–36. http://dx.doi.org/10.31617/visnik.knute.2022(143)10.

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Introduction. In the context of economic globalization, the role of international groups of companies (MNE Group). States are improving tax control over the payment of MNE Groups’ taxes, in particular, much attention is given to the rules of transfer pricing (TP). The TP rules are becoming more and more complex and it is important for enterprises to build an effective management system of the transfer pricing of the company and develop a policy on transfer pricing to minimize tax risks from the transfer pricing. Problem. The accounting of controlled transactions (CT) is an important element

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Kurfi, Shafi’u Abubakar, Noraza Mat Udin, and Usman Muhtari Tsohuwar Kasuwa. "Transfer Pricing and the Regulations in Nigerian Milieu." Indian Journal of Finance and Banking 1, no. 1 (2017): 33–41. http://dx.doi.org/10.46281/ijfb.v1i1.83.

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The main objective of this paper is to provide an overview of the transfer pricing practices and highlight the newly adopted regulations on transfer pricing in Nigeria. Due to the increase numbers of multinational corporations in the country, reports show that the transfer pricing activities by these entities has resulted in economics lost and a large amount of net resources being carried way from the region. These unethical exercises had signal clearly of the serious need to amend the massive leakages of economic resources. Over decades, Nigeria has worked tirelessly to develop its own transf

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Martins, António, Sandrina Correia, and Daniel Taborda. "Group Transactions, Transfer Pricing and Litigation: Evidence from Portugal." Intertax 48, Issue 11 (2020): 998–1011. http://dx.doi.org/10.54648/taxi2020101.

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In Portugal, in the wake of the introduction of tax arbitration in 2011, courts have ruled in several cases involving transfer pricing (TP) judicial conflicts. The research questions that this article addresses are: What are the core issues in TP litigation in Portugal? Do they follow international trends? What is the predominant outcome of arbitration rulings, and why do tax authorities experience defeat so many TP cases? Based on the total (thirty-two) TP arbitration cases decided in Portugal from 2012 to 2017, the authors find that tax administrations (TA) were successful in only three case

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Eukeria, Wealth, and Favourate Yelesedzani Mpofu. "Manipulation of Transfer Pricing Rules by Multinational Enterprises in Developing Countries: The Challenges and Solutions." Journal of Tax Reform 10, no. 1 (2024): 181–207. http://dx.doi.org/10.15826/jtr.2024.10.1.164.

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Domestic revenue mobilisation has become a topical issue in developing countries, and their capacity to regulate multinational enterprises (MNE) transactions to minimise Base Erosion and Profit Shifting (BEPS) remains a formidable task. Faced with legislative deficiencies, implementation incapacities, and being at the nascent stages of adopting transfer pricing (TP) regulation, developing countries have remained at the mercy of MNEs’ BEPS practices. The complexity and intricacies of intragroup transactions have an impact on profit allocation, thus affecting the distribution of taxing rights ac

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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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Togatorop, Ginda, Haula Rosdiana, and Milla Sepliana Setyowati. "Transfer Pricing Audit Policy Design Toward A Fair Tax System In Indonesia." Asian Journal of Engineering, Social and Health 3, no. 6 (2024): 1207–22. http://dx.doi.org/10.46799/ajesh.v3i6.338.

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The execution of transfer pricing (TP) audit policies, aimed at deterring tax evasion activities and ensuring adherence to the arm's length principle (ALP) among affiliated parties, is scrutinized in this investigation. This study adopts a qualitative research approach encompassing post-positivism and constructivism, employing data analysis methodologies like triangulation techniques and utilizing NVivo tools such as Coding. The research seeks to elucidate and scrutinize the enforcement of transfer pricing audit policies, pinpoint factors affecting their execution, and devise strategies for ma

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Cipollini, Claudio. "Blockchain and Smart Contracts: A Look at the Future of Transfer Pricing Control." Intertax 49, Issue 4 (2021): 315–32. http://dx.doi.org/10.54648/taxi2021030.

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This article aims to outline the path towards the future of transfer pricing (TP) control by exploring the new possibilities of blockchain and smart contracts and their potential impact on the international and European policy debate. After the introduction of some preliminary concepts, the first outcome is the identification of a uniform methodology for coding advance pricing agreements (APAs) into smart contracts in which conventional elements properly match with computer language components. Despite the challenges of the coding process and the issue of legal prose, the research also approac

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Milojević Kolarević, Maja. "VAT Implications of Transfer Pricing in Serbia – Joining the Incompatible." Harmonius Journal of Legal and Social Studies in South East Europe 13, no. 1 (2025): 160–92. https://doi.org/10.51204/harmonius_24106a.

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Adjustments to transfer pricing (TP) have been a subject of intense scrutiny within international taxation and customs procedures. This paper provides a comprehensive survey of global practices and regulatory frameworks, focusing on Serbia’s legal approach influenced by OECD standards and EU regulations. It examines the alignment of related party transactions with the arm’s length principle, the impact of TP adjustments on corporate income tax (CIT), value-added tax (VAT), and customs valuation, and the challenges faced by multinational enterprises (MNEs). The study argues that TP adjustments

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Fabio, Massimo. "Customs Value and Transfer Pricing: WCO and ICC Solutions to Be Adopted by Customs Authorities." Global Trade and Customs Journal 15, Issue 6 (2020): 273–87. http://dx.doi.org/10.54648/gtcj2020069.

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Intercompany transactions represent nowadays more than 60% of the total market. Businesses dealing with cross-border trade need to comply with the Transfer Pricing (TP) rules for income tax purposes and are obliged to reconcile transfer pricing adjustment with customs value. Such a reconciliation under the traditional customs approach is really burdensome. Just recently, World Customs Organization (WCO) took note of this issue and invited all customs authorities to apply the International Chamber of Commerce (ICC) solutions to ease the customs relation and speed the international trade. The mo

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Eriotis, Nikolaos, Spyros Missiakoulis, Ioannis Dokas, Marios Tzavaras, and Dimitrios Vasiliou. "Tax Avoidance and Transfer Pricing." International Journal of Corporate Finance and Accounting 8, no. 2 (2021): 28–39. http://dx.doi.org/10.4018/ijcfa.2021070103.

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Globalization has led multinational companies, beyond intensifying their competitiveness, to seek ways to maximize profits through tax avoidance. The international character enables them to transfer profits to tax havens or seek transactions that will enable them to avoid, postpone, or pay lower taxes. Although the previous allegations have been hypothesized by researchers, tax audits, and governments, it is difficult to prove due to the chaotic data and the causal relationship between variables. The present study compared the tax burden of 971 multinationals and 1,160 independent companies fo

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Fulop, Renata. "Key observations on factors influencing transfer pricing practices: A comparative review." International Journal of Economic Practice and Policy 21, no. 1 (2024): 76–89. https://doi.org/10.5937/skolbiz1-52059.

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The contemporary business landscape, shaped by economic globalization, technological advancements, and increased cross-border transactions, presents both challenges and opportunities for global enterprises. Within this dynamic context, the strategic operations of multinational corporations are significantly influenced by transfer pricing decisions. This article undertakes a comprehensive exploration of the intricate factors that contribute to the shaping of TP decisions, leveraging insights from a diverse range of studies spanning multiple decades. The primary objective is to identify the fact

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Tambunan, Maria R. U. D. "A SAFE HARBOUR: A PREDETERMINED MARGIN METHOD TO REDUCE TRANSFER PRICING COMPLIANCE BURDEN." Mimbar Hukum 33, no. 2 (2021): 521–46. http://dx.doi.org/10.22146/mh.v33i2.2277.

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Abstract The safe harbour provision was unpopular since the beginning of transfer pricing (TP) implementation in Indonesia, even though this provision has been well-known in several countries. Indonesia’s existing safe harbour provision has solely governed the threshold on TP documentation obligation that could not offer certainty about tax audit treatment. The TP threshold refers to the total transaction volume per fiscal year with an affiliation that allows taxpayers to get relief from submitting TP documentation. A deemed profit also applies to a certain manufacture contract. With current p

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Mukhtaruddin, Jerikho Tanujaya, and Umi Kalsum. "Transfer Pricing and Tax Avoidance: A Study on Manufacturing Companies Listed in Indonesia." International Journal of Accounting and Economics Studies 12, no. 2 (2025): 194–202. https://doi.org/10.14419/5fxgv314.

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Tax avoidance (TA) is the practice of taxpayers taking advantage of gaps in tax laws to lower or minimize their tax liability. The purpose of this study is to investigate how transfer pricing (TP) affects TA practices. All manufacturing companies listed on the Indonesia Stock Exchange between 2019 and 2023 make up the research population. Purposive sampling was used to determine the sample, and 17 companies with a 5-year observation period were selected, yielding 85 observations in total. Regression analysis is the method employed. The impact of TP on TA can be managed by factors such as forei

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Mwape, Victor, Austin Mwange, and Munyonzwe Hamalengwa. "Reconciling Global Norms and Local Realities: An Assessment of Zambia’s Legislative and Institutional Framework on Transfer Pricing Regulation." African Journal of Commercial Studies 6, no. 2 (2025): 204–14. https://doi.org/10.59413/ajocs/v6.i2.20.

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Transfer pricing (TP) regulation has become a central concern in global tax governance, particularly in resource-rich developing countries susceptible to base erosion and profit shifting by multinational enterprises (MNEs). This article critically evaluates Zambia’s legislative and institutional framework for transfer pricing, focusing on its alignment with the OECD Transfer Pricing Guidelines and the United Nations Practical Manual. Drawing upon Zambia’s Income Tax Act, statutory instruments, practice notes, and the evolution of regulatory amendments from 1999 to 2023, the study explores the

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Simbolon, Deliyanti, and Asianna Martini Simarmata. "Pengaruh Pajak Penghasilan Tunneling Incentive Terhadap Keputusan Transfer Pricing pada Perusahaan Subsektor Industri Dasar dan Kimia Bursa Efek Indonesia." Jurnal Penelitian Inovatif 4, no. 1 (2024): 97–104. http://dx.doi.org/10.54082/jupin.268.

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Penelitian bertujuan untuk mengetahui apakah Pajak Penghasilan, Tunneling Incentive berpengaruh terhadap Keputusan Transfer Pricing pada subsektor industri dasar dan kimia di Bursa Efek Indonesia. Jenis data yang digunakan penelitian ini data kuantitatif dan sumber data berupa data sekunder. Data sekunder penelitian ini berupa laporan keuangan keuangan tahunan selama periode 2018-2022. Populasi penelitian ini perusahaan sektor industri dasar dan kimia yang terdaftar di Bursa Efek Indonesia selama periode penelitian sebanyak 71 perusahaan. Sampel penelitian 9 perusahaan dengan teknik purposive

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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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Bronzewska, Katarzyna, and Filip Majdowski. "Revolutionary Changes to the Arms Length Principle under the OECD BEPS Project: Have CFC Rules Become Redundant?" Intertax 46, Issue 3 (2018): 210–24. http://dx.doi.org/10.54648/taxi2018023.

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Title question of the article is deliberately provocative. The subject of interactions between Controlled Foreign Company (CFC) regulations and transfer pricing (TP) regulations is a complex topic that has been bringing divergent opinions over many decades (In United States, from where both CFC regime and TP regime originated, the literature on this subject has been present at least since 1969, being no more than one year after the introduction of detailed US TP regulations (1968). CFC regulations – Subpart F – was introduced therein in 1962. See for instance: L. Kauder, Taxation of Domestical

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Solilová, Veronika. "Transfer pricing rules in EU member states." Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis 58, no. 3 (2010): 243–50. http://dx.doi.org/10.11118/actaun201058030243.

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One of the important area of international taxes is transfer pricing. Transfer price is a price set by a taxpayer when selling to, buying from, or sharing resources with a related (associated) person. The transactions between these persons should be assessed at their arm’s length price in according the arm’s length principle – international accepted standard – as the price which would have been agreed between unrelated parties in free market conditions. This paper is focused on the tranfer pricing rules used in particular EU Member States so as if EU Member States apply the arm’s length prin

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Ardi, Wijang, Ulfa Maulida, Maria Ulfah Kusumaastuti, Indra Pahala, and Puji Wahono. "Tax Crime Risk in Mining Sector Companies : An Examination of Transfer Pricing Analysis and Capital Intensity." Moneter: Jurnal Keuangan dan Perbankan 12, no. 2 (2024): 250–57. http://dx.doi.org/10.32832/moneter.v12i2.756.

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This research investigates how capital intensity and transfer pricing may affect the likelihood of tax offenses in the mining industry. The report uses a sample of mining businesses listed from 2018 to 2022 on the Indonesian Stock Exchange (IDX) and using a quantitative research technique. The research examines the links between the dependent variable, which is represented by the cash effective tax rate (CETR), and the independent variables, transfer pricing (TP) and capital intensity (CAP), using multiple regression analysis and a legal approach. The corporations' transfer pricing methods and

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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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Martins, António F. "Accounting information and its impact in transfer pricing tax compliance: a Portuguese view." EuroMed Journal of Business 12, no. 2 (2017): 207–20. http://dx.doi.org/10.1108/emjb-11-2016-0029.

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Purpose In transfer pricing (TP) methods, especially when based on margins, accounting indicators are of paramount relevance to assess the profitability of firms, and to compare such indicators to samples of similar companies. The purpose of this paper, drawing on the legal research method, is to discuss the following questions: when using the transactional net margin, quite common in TP tax reporting, does the new (IFRS-based) Portuguese financial accounting system produce profit level indicators that are closer to the underlying reality that TP aims to capture, or are these profit level indi

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Hidayah, Retnoningrum, Dhini Suryandari, Heri Yanto, et al. "The influence of foreign ownership and debt covenant on transfer pricing: A study of corporate governance." Journal of Governance and Regulation 14, no. 2 (2025): 49–57. https://doi.org/10.22495/jgrv14i2art5.

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The business world is developing very rapidly in countries. Transfer pricing (TP) is vital in multinational companies (Kumar et al., 2021). This study analyzes the influence of foreign ownership (FO) and debt covenants on TP with multinationality as a moderating variable. The research population is manufacturing companies listed on the Indonesia Stock Exchange (IDX). The sample used the purposive sampling method. This study uses the partial least squares structural equation modeling (PLS-SEM) method to test the research hypotheses. The results prove that FO does not affect TP and debt covenant

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LIPKA, Krzysztof. "EU AND TRANSFER PRICING. TOWARD PETRIFICATION OR REVOLUTION?" Journal of Public Administration, Finance and Law 29 (2023): 311–20. http://dx.doi.org/10.47743/jopafl-2023-29-26.

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Two EU documents important for transfer pricing were announced in 2021 and 2023. The first one is a framework of the EU’s tax strategy disclosed in a document called “Communication on Business Taxation for the 21st century” published in 2021. The next one is Transfer Pricing Directive (TPD) proposal published in 2023. TPD proposes cementing current TP rules proposed by OECD decades ago. The first document contains some very significant proposals, one of which calls for the introduction of a new taxation mechanism imposed on “groups of companies “as the term is used in the document. This new ta

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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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Dahlan, Muhammad. "QUALITATIVE ANALYSIS OF TRANSFER PRICING AUDITS IN LIGHT OF COVID-19 DISRUPTIONS: INDONESIAN CONTEXT." Scientax 3, no. 2 (2022): 227–47. http://dx.doi.org/10.52869/st.v3i2.80.

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A Qualitative Analysis of Transfer Pricing Audits in Light of COVID-19 Disruptions: Indonesian Context. The global economy and financial markets are now suffering from one of the strongest threats in modern history, an outbreak of Corona Virus Disease 2019 (COVID-19). The main objective of the paper is to contribute to the development of transfer pricing audits due to COVID-19 disruptions in Indonesian context. Furthermore, this paper intends to draw a theoretical framework on tax audits policy from a qualitative perspective. In conducting transfer pricing audits in relation with COVID-19, tax

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ДИВИНА Л.Э., ДИВИНА Л. Э. "TRANSFER PRICING: PAST, PRESENT AND FUTURE." Экономика и предпринимательство, no. 4(165) (June 25, 2024): 1161–64. http://dx.doi.org/10.34925/eip.2024.165.4.233.

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В статье автор рассматривает основные концепции трансфертного ценообразования в эпоху до и после BEPS, а также выдвигает ряд соображений, основанных на существующих дискуссиях о проблеме размывания налоговой базы и вывода прибыли из-под налогообложения. Глобализация, в том числе цифровая трансформация приводят к размытию традиционных границ между странами, а также к возникновению новых видов товаров, услуг и активов, которые могут быть переданы между связанными сторонами. Автор заключает, что ТЦП должно развиваться в соответствии с новыми вызовами, которые возникают в результате глобальных изм

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Ramadhan, Fadilah Amal, and Dyah Purnamasari. "Pengaruh Transfer Pricing, Profitabilitas, dan Leverage Terhadap Penghindaran Pajak (Studi Empiris Pada Perusahaan Coal Production Yang Terdaftar Di BEI 2019-2023)." Owner 9, no. 2 (2025): 1548–68. https://doi.org/10.33395/owner.v9i2.2716.

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Tax avoidance remains a major challenge for state revenues, especially in sectors that are vulnerable to fiscal manipulation, such as the coal industry. This study aims to examine the partial effect of transfer pricing, profitability, and leverage on tax avoidance in coal companies listed on the Indonesia Stock Exchange (IDX) during the period 2019–2023. The study uses a quantitative approach based on secondary data obtained from the company's financial statements on the official IDX website and each company. Through a purposive sampling technique, 10 companies were selected from 34 population

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Ilham, Muhammad, and Budiasih Widiastuti. "Hambatan Penyelesaian Sengketa Transfer Pricing Melalui Mutual Agreement Procedure (MAP) Di Indonesia." Educoretax 2, no. 1 (2022): 20–34. http://dx.doi.org/10.54957/educoretax.v2i1.129.

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Penelitian ini bertujuan untuk mengetahui apa sebenarnya permasalahan mendasar yang dihadapi dalam penyelesaian sengketa koreksi Transfer Pricing (TP) melalui MAP di Indonesia. Penelitian ini dilakukan dengan metode kualitatif dalam rangka mengamati fenomena yang terjadi pada praktik penyelesaian MAP. Data yang digunakan yaitu, data primer berupa hasil wawancara terstruktur dan data sekunder berupa data dan informasi yang diperoleh dari buku, jurnal, laporan, hasil penelitian, dan peraturan yang diterbitkan oleh pemerintah. Hasil penelitian ini menunjukkan bahwa hambatan yang terdapat di dalam

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Iugina, Anastasiia Andreevna. "Approach to reporting on transfer pricing in the CIS countries." Налоги и налогообложение, no. 1 (January 2022): 57–64. http://dx.doi.org/10.7256/2454-065x.2022.1.36207.

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The article examines the main obligations of taxpayers in various CIS countries and their differences in comparison with the approach adopted by the OECD countries, in particular, the widespread obligation to file notifications of controlled transactions, the specifics of the requirements for filing three-level reporting, etc. The object of the study is the provisions of the legislation of the analyzed countries in the field of transfer pricing, by-laws and regulations issued by individual public authorities, and the subject of the study is the main regularities of regulation, as well as diffe

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Nasikhudin, Nasikhudin, and Supriyadi Supriyadi. "Analysis of interest expense deduction in transfer pricing dispute in Indonesia." Educoretax 4, no. 9 (2024): 1137–48. http://dx.doi.org/10.54957/educoretax.v4i9.1115.

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This study provides a comprehensive examination of interest expense disputes within the context of transfer pricing in Indonesia. Multinational enterprises frequently employ transfer pricing mechanisms to reduce their tax obligations, often leading to legal challenges in tax courts. The research employs a qualitative methodology, focusing on a detailed analysis of several tax court verdicts related to interest expense disputes. The primary dataset comprises appellate verdicts available from the official tax court repository. The study identifies key factors influencing the outcomes of such dis

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Srivastava, Rakesh Narain, and Charu Singh. "Effect of Environmental Factors on the Choice of Transfer Pricing Policies: An Analysis of a Few Indian Multinational Corporations." Journal of Entrepreneurship and Management 14, no. 2 (2025): 11–23. https://doi.org/10.21863/jem/2025.14.2.002.

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The global trade market is unstable and unpredictable due to shifting environmental circumstances. The variables determining transfer pricing policies will change over time and in relation to different geographic locations. A single universally applicable TP does not exist, as host nation governments would be efficient in organising defences. The study includes environmental variables in order to assess the influence and trends of the same in the choice of Transfer Pricing policies employed by MNCs. Eighteen environmental variables were selected for data collection, and respondents rated the s

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Brychta, Karel, Matheus Chebli de Abreu, Justina Hudenko, Lucas Scheremetta Santos, and Lucas Cunha do Valle Poubel. "The concept of associated persons as a key and potentially problematic aspect in transfer pricing." Financial Internet Quarterly 19, no. 1 (2023): 21–33. http://dx.doi.org/10.2478/fiqf-2023-0003.

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Abstract Transfer pricing (TP) is based on many principles – the essential one is the Arm´s Length Principle (ALP). In this respect, the term “associated persons” is of crucial importance: associated persons must be involved in transactions in order for the ALP to be applied. The aim of the paper is to contribute to existing comparative analysis of TP rules – specifically, to provide a critical analysis of the term “associated persons” as prescribed by domestic law in Brazil, the Czech Republic, and Latvia. The key goals of the research conducted were to provide a comprehensive picture of the

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Mwape, Victor, Munyonzwe Hamalengwa, and Austin Mwange. "Evaluating Transfer Pricing Methodologies for Multinational Enterprises in Zambia: A Critical Appraisal of OECD-Compliant Approaches and Local Implementation Challenges." East African Finance Journal 4, no. 2 (2025): 129–39. https://doi.org/10.59413/eafj/v4.i2.8.

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This article undertakes a critical examination of the principal transfer pricing (TP) methodologies endorsed by the Organisation for Economic Co-operation and Development (OECD) and the United Nations (UN), focusing on their applicability within Zambia’s legal and economic environment. Specifically, it evaluates the five primary TP methods—the Comparable Uncontrolled Price (CUP), Resale Price Method (RPM), Cost-Plus Method (CPM), Transactional Net Margin Method (TNMM), and the Transactional Profit Split Method (TPSM)—in the context of Zambia’s mining-dominated economy and limited comparable ma

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Vinti, Agrawal. "Corporate Guarantee: Computation of Guarantee Fees at Arm’s Length Price." Christ University Law Journal 5, no. 1 (2016): 19–34. http://dx.doi.org/10.12728/culj.8.2.

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The most recent controversy surrounding Indian tax courts, pertains to the issue of international transactions with respect to intra-group financing. It includes short as well as long term borrowing and lending, guarantees etc. The debate centres around transfer pricing (herein after referred to 'TP') provisions and how the computation of arm’s length price is to be done. The article has focussed on one aspect of intra group financing, that is, the provision of corporate guarantee. The paper first describes the meaning of guarantee and then highlights various provisions relating to corporate g

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Mariana, MUZYCHUK, and FOMINA Olena. "CbC-REPORTING IN TAX ADMINISTRATION." Foreign trade: economics, finance, law 116, no. 3 (2021): 64–76. http://dx.doi.org/10.31617/zt.knute.2021(116)06.

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Background. Countering the erosion of the tax base through the use of transfer pricing (TP) is an important element of tax policy. Ukraine is implementing three-level TP reporting and the procedure of automatic exchange of tax information. The analysis of recent research and publications has showedthat research on the use of data obtained in the exchange of tax information procedure under the CbC standard is relevant and controversial. The aim of the articleis to investigate the conditions for the introduction of automatic information exchange in Ukraine and provide recommendations for the pra

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Nitin, S. Kondalwade Patil, and Rautdesai Rupal. "Marketing Intangibles – The Legal Quest of Quantifying the Non-Measurable." International Journal of Management and Humanities (IJMH) 4, no. 6 (2020): 59–68. https://doi.org/10.35940/ijmh.F0606.024620.

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AMP1 commonly referred as issue of marketing intangible in the Transfer Pricing (‘TP’) has been on the top list of revenue authorities for scrutiny not only in India but worldwide. In India, the issue has travelled through various Income tax ITATs to the various High courts. Still the same has not attained the required finality till date. The issue has been contested on various debates involving issue of consideration of incurrence of AMP expenditure as an international transaction, recovery of such expenses from associated enterprise (‘AE’), incurrence of AMP leading t

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Rinnert, Sandra, and Michael Lux. "Are Flat Rate Adjustments of the Customs Value Possible on the Basis of a Transfer Price Arrangement?: Judgment of the German Federal Fiscal Court in ‘Hamamatsu’ following the ECJ Judgment C-529/16." Global Trade and Customs Journal 18, Issue 4 (2023): 126–38. http://dx.doi.org/10.54648/gtcj2023015.

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In C-529/16 the Munich Fiscal Court had asked the European Court of Justice (ECJ) whether the customs valuation provisions of the Community Customs Code (CCC) in force at the time of the events permit an agreed transfer price, which is composed of an amount initially invoiced and declared, and a flat-rate adjustment made after the end of the accounting period using an allocation key, regardless of whether a subsequent debit charge or credit is made to the declarant at the end of the accounting period, and if so, whether the customs value may be reviewed and/or determined using simplified appro

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See, J. C. "Introduction of TP Penalties." International Transfer Pricing Journal 25, no. 5 (2018). http://dx.doi.org/10.59403/1m29829.

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The cost of non-compliance for transfer pricing (TP) in Singapore has recently increased tenfold, and maybe more, under the newly introduced formal legislation mandating the preparation of contemporaneous transfer pricing documentation. The changes mark the beginning of a formal, legislation-based transfer pricing regime, and is part of the increasing emphasis the Singapore tax authorities place on transfer pricing compliance.

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Coronado, L., H. Syrett, and V. Danabalan. "Issuance of the 2015 Singapore TP Guidelines." Asia-Pacific Tax Bulletin 21, no. 2 (2015). http://dx.doi.org/10.59403/6b2kvq.

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This article is a continuation of the previous article in IBFD’s Asia-Pacific Tax Bulletin dated November/ December 2014 (Volume 20, - Number 6, - 2014), wherein the authors provided comments with regard to the key differences between the IRAS consultation paper on the transfer pricing guidelines and the final OECD report on Action 13. The revised guidelines were released by IRAS on 6 January 2015, and this article summarizses again the main similarities and differences between the key compliance issues in Section D of the final OECD report on Action 13 and the 2015 Singapore Transfer Pricing

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Hassan, B. "Saudi Arabia Publishes New Transfer Pricing Guidelines for Qualified Taxable Persons." International Transfer Pricing Journal 28, no. 1 (2020). http://dx.doi.org/10.59403/3eff5jd.

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On 30 May 2020, Saudi Arabia published new transfer pricing (TP) guidelines to provide insight and guidance concerning the TP practice in Saudi Arabia based on the application of the TP Bylaws. In this article, the author summarizes those TP guidelines with the objective of updating the qualified taxable persons regarding their legislative and administrative responsibilities under the TP regulations and to enable them to better understand the TP regulatory framework and TP documentation requirements in Saudi Arabia.

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