Transfer pricing comparables: Preferring a close neighbor over a far-away peer?

Steens, Bert; Roques, Thibaut; Gonnet, Sébastien; Beuselinck, Christof; Petutschnig, Matthias

doi:10.1016/j.intaccaudtax.2022.100471

Cited by 4 publications

(3 citation statements)

References 43 publications

Supporting

Mentioning

Contrasting

Order By: Relevance

“…However, regulations that are too lax result in a "race to the bottom" due to tax competitiveness, which removes all incentives for FDI driven by tax considerations. Steens et al (2022), analyzed the effect of country risk level (proxied by S&P country rating and risk indicators from ICRG and WGI) on firm profitability (measured by ROS) using an uncontrolled sample of manufacturing firms, revealing that there is a positive relationship between country risk level and profitability. By using…”

Section: Resultsmentioning

confidence: 99%

“…These calculations apply to transactions involving business units within the same corporate group but located in separate geographic zones. The tax issue stems from the difficulty of proving that intercompany pricing adhere to the "arm's length" principle and from the associated worry that multinational corporations (MNCs) may be able to selectively alter cross-border transfer prices to move profits from high-tax to low-tax nations (Beuselinck et al, 2015;De Simone, 2016;Klassen et al, 2017;Steens et al, 2022;Wier, 2020).…”

Section: Introductionmentioning

confidence: 99%

See 1 more Smart Citation

Transfer Pricing at Multinational Corporate: A Literature Review Approach

Huslyanti,

Khaddafi,

Iswadi

2023

j. manaj. Indonesia

View full text Add to dashboard Cite

This study is the result of a literature review of 10 (ten) articles on transfer pricing in multinational corporations (MNCs) studied by researchers from various countries both developed and developing countries in terms of objectives, methods and results. The ten (10) articles reviewed are sourced from international journals namely sciendirect and emerald insight. The study results show that in general, the purpose of the articles is to address transfer pricing abuse in multinational companies. The method used is generally quantitative and the result is that transfer pricing is related to tax avoidance.

show abstract

Section: Resultsmentioning

confidence: 99%

Section: Introductionmentioning

confidence: 99%

Transfer Pricing at Multinational Corporate: A Literature Review Approach

Huslyanti,

Khaddafi,

Iswadi

2023

j. manaj. Indonesia

View full text Add to dashboard Cite

show abstract

“…This can be a serious problem, especially for SMEs, which provokes reasonable efforts to find simplified solutions -the establishment of safe harbours is one of them (Solilová et al, 2019). A safe harbour as such can be applied, "(…) for low-risk transactions which relieves taxpayers of certain obligations which would otherwise be required under that coun-try´s transfer pricing rules" (Mills, 2019(Mills, , p. 1077, while application of the full scope of TP rules is connected, among other aspects, with the absence of reliable data and necessary adjustments of those available (see Steens et al, 2022). The complexity/intricacy of the standards (arising also partly due of their general nature) brings uncertainty for both taxpayers and tax administrators.…”

mentioning

confidence: 99%

Challenges in transfer pricing: A concept of safe harbours for financial transactions

Ištok

Solilová

Brychta

2022

Financial Internet Quarterly

View full text Add to dashboard Cite

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 responses to all potential problems and circumstances – they provide fundamental ideas and principles. Thus, the potential to apply a simplified procedure for setting a transfer price (even for financial transactions) can be viewed as desirable, both for taxpayers and tax authorities. The aim of the paper is linked to this idea – to present the results of a comparative study dealing with the rules for safe harbours for financial transactions (namely loans) as established worldwide, providing a summary of existing concepts and systematized criteria for a safe harbour to be considered.

show abstract