A Guide to Global Transfer Pricing Strategy

Feinschreiber, Robert; Kent, Margaret

doi:10.1002/jcaf.1105

Cited by 7 publications

(8 citation statements)

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“…Meanwhile, Liu, Schmidt-Eisenlohr, and Guo (2020) state that transfer pricing is the determination of prices for internal (intra-company) transactions of goods, services, intangible assets and capital flows within multinational companies. This is in line with the definition of transfer pricing in the context of taxation by Feinschreiber (2004), who stated that transfer pricing is the determination of transaction prices between affiliated companies. These transactions may include sales, licenses, rentals, services, and interest.…”

Section: Tax Evasionsupporting

confidence: 82%

effect of transfer pricing, thin capitalization, deferred tax, and inventory intensity on tax avoidance

Ardiles,

Yuliansyah,

Suhendro

2024

Journal of Multidisciplinary Academic and Practice Studies

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Purpose: This study aims to determine the effect of transfer pricing, thin capitalization, deferred tax, and inventory intensity on tax avoidance. Method: This study uses a quantitative approach with a sample consisting of all companies listed on the Indonesia Stock Exchange (BEI) from 2018 to 2022. A purposive sampling technique was used for sample selection, and a sample of 107 companies was obtained. This study uses panel data analysis. Result: The results of the analysis show that thin capitalization and deferred taxes have a negative effect on tax avoidance, while transfer pricing and inventory intensity have no effect on tax avoidance.

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Section: Tax Evasionsupporting

confidence: 82%

effect of transfer pricing, thin capitalization, deferred tax, and inventory intensity on tax avoidance

Ardiles,

Yuliansyah,

Suhendro

2024

Journal of Multidisciplinary Academic and Practice Studies

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“…The arm's length principle is the method that the tax authorities calculate the tax obligations of the companies, which participate in international transactions. The authorities using the arm's length principle are tough to obtain the controlled transactions, as the international companies offer similar data with that of the uncontrolled transactions and they are hiding with a purpose to avoid paying taxes (Feinschreiber, 2004). Therefore, the government needs to apply the fixed-length principle.…”

Section: Review Of Literaturementioning

confidence: 99%

Untitled

2021

IJBESAR

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Research Articles: A research article is a regular article which aims to present new findings. 2. Letters to the Editor: A letter to the editor is a short article which aims to present new findings that require fast publication procedures. 3. Notes: A note is an article (regular or short) which aims to present rather new findings. 4. Comments: A comment is a short article that makes comments on another article already published by this journal or replies to a comment; 5. Review Articles: A review article is an article which aims to present comprehensively already existing findings.6. Lecture Notes: A lecture note is a short review article. 7. Monographs: A monograph is a thesis of one or more authors on a unique subject; apart from the standard reviewing procedures, a monograph must also be accepted from a committee of specialists appointed by the Editor. 8. Innovations: An innovation is an article which aims to present new procedures or devices. 9. Selected conference articles: Upon an agreement with a conference committee, selected papers may be published by the Journal in a special section. In this case the editor will appoint in collaboration with the conference committee guest editors.

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“…The profit split method is used to determine the market price for such operations. The more unique tangibles and intangibles are, the greater the chance for MNEs to shift income (Feinschreiber, 2004). Other methods are mainly used to make close estimations of the market value of internally traded intangibles, via different profit ratio comparisons.…”

Section: Definitions and Mne's Transfer Pricing Guidelinesmentioning

confidence: 99%

A Review of Empirical Studies on Transfer Pricing Manipulation

Jarallah¹,

Kanazaki²

2011

Journal of International Logistics and Trade

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This research surveys the recent surge of empirical studies on transfer pricing manipulation by multinational enterprises (MNEs), tax-motivated transfer pricing, particularly from the year 1990 to present. The review tackles transfer pricing income shifting behavior of MNEs from three different perspectives: taxation relationship with profitability, intrafirm trade, and foreign direct investment (FDI). There have been significant developments and contributions in this field, despite many limitations, mainly concerning the availability of micro-data in general, (specifically intrafirm trade data which allows capturing much of the heterogeneity which is dangling within inter-sectors), and the tax measurement issue. Yet, this area of study is still developing and promises more achievements.

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A Guide to Global Transfer Pricing Strategy

Cited by 7 publications

References 0 publications

effect of transfer pricing, thin capitalization, deferred tax, and inventory intensity on tax avoidance

effect of transfer pricing, thin capitalization, deferred tax, and inventory intensity on tax avoidance

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A Review of Empirical Studies on Transfer Pricing Manipulation

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