28Feb 2017

TRANSFER PRICING: CONCEPTS, EVOLUTION, METHODS, EXISTING GUIDELINES AND ITS EFFECTS IN DEVELOPING COUNTRIES.

  • Cihan University, College of Financial and Administration, Sulaiymani, Kurdistan Region, Iraq.
Crossref Cited-by Linking logo
  • Abstract
  • Keywords
  • References
  • Cite This Article as
  • Corresponding Author

Transfer pricing is high on the agenda because globalization has lifted the level of cross-border trade between related entities to new heights. It is estimated that, worldwide, about 2/3 of all business transactions take place within a group. In the absence of Transfer Pricing legislation, both tax administrations and MNEs have only limited guidance they can refer to when determining transfer pricing in related-party transactions. However, we find that developing countries encounter particular problems when dealing with transfer pricing. Local tax administrations are often inexperienced with regard to transfer pricing and lack basic understanding in the field. The paper indicates that, despite strong affinity to the OECD standards, the scope of existing transfer pricing legislation or draft transfer pricing legislation is in part significantly broader as regards the definition of related parties than is outlined in the OECD Guidelines. From a transfer pricing policy perspective


  1. Anderson, Anders,? K, R. And?? Grimson, A . 2003.?? SMG-5 required for? C.elegans? nonsense-mediated? mRNA decay,associates with SMG-2 and protein phosphatase? 2A. The EMBO? journal, VOL 22 No. 3 pp, 641-650.
  2. Bartelsman, E , j. and Beetsma, R , M.W.J. W hy pay more? Corporate tax avoidance through transfer pricing in OECD countries. Journal of Public Economics 87 2225?2252.
  3. Bernard, A, B. Jensen, J, B. and Schott, P, K. 2006. Trade costs, firms and productivity. Journal of Monetary Economics 53 .917?937.
  4. BUUS, T. BRADA, J. 2010. VAT and Tax Credits: A Way to Eliminate Tax-Evasive Use of Transfer Prices?.European Financial and Accounting Journal,
  5. Cernic, J, L. 2008. Corporate responsibility for human rights: A Critical analysis of the OECD Guidelines for multinational enterprises. International law /internationals recht.
  6. Clausing, K, A. 2001. T ax-motivated transfer pricing and US intra firm trade prices.Journal of Public Economics 87 .2207?2223.
  1. Chow, Chan You. "Automatic routing of incoming telephone calls to a plurality of receiving devices based on caller identification." U.S. Patent No. 5,644,629. 1 Jul. 1997.
  2. Cools, M. 2003. ?Increased Transfer Pricing Regulations: What about the Managerial Role of Transfer Pricing?? International Transfer Pricing Journal July/August. Vol. 10 (2003), no. 4; p. 134-140.
  1. Dolman, Ben, David Gruen, and Australian Treasury. "Productivity and structural change."?41st Australian Conference of Economists. Vol. 10. 2012.
  2. Eden, L. And Rodriguez, P. 2004. How weak are the signals? International price indices and multinational enterprises. Journal of International Business Studies?35,?61?74.
  1. Gresik, T, A. 2001. The taxation task of taxing transnationals. Journal of Economic Literature. Vol. 39, No. 3, pp. 800-838.
  2. Gruen, David, and Australian Treasury. "The macroeconomic and structural implications of a once-in-a-lifetime boom in the terms of trade."?Address to the Australian Business Economists Annual Conference. Vol. 24. 2011.
  3. Smith, A. Chambers, I. Nichols, J And Ying, Q. 2003. BMP Induction of Id Proteins Suppresses Differentiation and Sustains Embryonic Stem Cell Self-Renewal in Collaboration with STAT3. Institute for Stem Cell Research University of Edinburgh King?s Buildings West Mains Road Edinburgh Scotland EH9 3JQ.

[Ali Abdulridha Jabbar. (2017); TRANSFER PRICING: CONCEPTS, EVOLUTION, METHODS, EXISTING GUIDELINES AND ITS EFFECTS IN DEVELOPING COUNTRIES. Int. J. of Adv. Res. 5 (Feb). 2003-2008] (ISSN 2320-5407). www.journalijar.com


Ali Abdulridha Jabbar
Lecturer

DOI:


Article DOI: 10.21474/IJAR01/3371      
DOI URL: http://dx.doi.org/10.21474/IJAR01/3371