Nothing Special   »   [go: up one dir, main page]
IDEAS home Printed from https://ideas.repec.org/a/aud/audfin/v134y2016i14p183.html
   My bibliography  Save this article

Transfer pricing documentation – an efficient measure for combating the base erosion and profit shifting?

Author

Listed:
  • Liliana FELEAGA

    (Bucharest University of Economic Studies)

  • Ioana NEAC?U

    (Bucharest University of Economic Studies)

Abstract
The setting up of groups of companies has become a large scale phenomenon, dominating the global economy. These groups have set up subsidiaries in different countries, leading to the occurrence of issues regarding the taxation of the results within the group, and to the development of the transfer pricing concept, respectively. This concept has been used over the time by multinational corporations to move their profits in low- tax jurisdictions. For this reason, globally, there have been concerns regarding the adoption of a legislation that could combat the base erosion and profit shifting. This article analyses whether the adoption of a legislation which provides the transfer pricing documentation requirement represents an efficient measure for the blurring of the base erosion and profit shifting phenomenon. The research was performed at the level of the member countries of the Organisation for Economic Co-operation and Development. The article also aims to clarify certain aspects regarding transfer pricing and to provide a practical approach of the associated mechanisms. The novelty, originality and impact of the article on the accounting profession are represented by the fact that the transfer pricing concept is relatively new for the specialists from Romania and also for the tax authorities.

Suggested Citation

  • Liliana FELEAGA & Ioana NEAC?U, 2016. "Transfer pricing documentation – an efficient measure for combating the base erosion and profit shifting?," The Audit Financiar journal, Chamber of Financial Auditors of Romania, vol. 14(134), pages 183-183, January.
    • Handle: RePEc:aud:audfin:v:134:y:2016:i:14:p:183
    as

    Download full text from publisher

    File URL: http://revista.cafr.ro/temp/Article_9455.pdf
    Download Restriction: no
    ---><---

    References listed on IDEAS

    as
    1. Peralta, Susana & Wauthy, Xavier & van Ypersele, Tanguy, 2006. "Should countries control international profit shifting?," Journal of International Economics, Elsevier, vol. 68(1), pages 24-37, January.
    2. Theresa Lohse & Nadine Riedel & Christoph Spengel, 2012. "The Increasing Importance of Transfer Pricing Regulations – a Worldwide Overview," Working Papers 1227, Oxford University Centre for Business Taxation.
    3. Bartelsman, Eric J. & Beetsma, Roel M. W. J., 2003. "Why pay more? Corporate tax avoidance through transfer pricing in OECD countries," Journal of Public Economics, Elsevier, vol. 87(9-10), pages 2225-2252, September.
    4. Kimberly A. Clausing, 2000. "The Impact of Transfer Pricing on Intrafirm Trade," NBER Chapters, in: International Taxation and Multinational Activity, pages 173-200, National Bureau of Economic Research, Inc.
    Full references (including those not matched with items on IDEAS)

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Thiess Buettner & Michael Overesch & Georg Wamser, 2018. "Anti profit-shifting rules and foreign direct investment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 25(3), pages 553-580, June.
    2. Peralta, Susana & Wauthy, Xavier & van Ypersele, Tanguy, 2006. "Should countries control international profit shifting?," Journal of International Economics, Elsevier, vol. 68(1), pages 24-37, January.
    3. Krautheim, Sebastian & Schmidt-Eisenlohr, Tim, 2011. "Heterogeneous firms, 'profit shifting' FDI and international tax competition," Journal of Public Economics, Elsevier, vol. 95(1-2), pages 122-133, February.
    4. Jean Hindriks & Yukihiro Nishimura, 2021. "Taxing multinationals: The scope for enforcement cooperation," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 23(3), pages 487-509, June.
    5. Petr Janský & Miroslav Palanský, 2019. "Estimating the scale of profit shifting and tax revenue losses related to foreign direct investment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 26(5), pages 1048-1103, October.
    6. Wolfgang Eggert & Jun-Ichi Itaya, 2014. "Tax Rate Harmonization, Renegotiation, and Asymmetric Tax Competition for Profits with Repeated Interaction," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 16(5), pages 796-823, October.
    7. repec:spo:wpecon:info:hdl:2441/3381 is not listed on IDEAS
    8. AMERIGHI, Oscar, 2004. "Transfer pricing and enforcement policy in oligopolistic markets," LIDAM Discussion Papers CORE 2004069, Université catholique de Louvain, Center for Operations Research and Econometrics (CORE).
    9. Hayato Kato & Hirofumi Okoshi, 2022. "Economic Integration And Agglomeration Of Multinational Production With Transfer Pricing," International Economic Review, Department of Economics, University of Pennsylvania and Osaka University Institute of Social and Economic Research Association, vol. 63(3), pages 1325-1355, August.
    10. Becker, Johannes & Davies, Ronald B. & Jakobs, Gitte, 2017. "The economics of advance pricing agreements," Journal of Economic Behavior & Organization, Elsevier, vol. 134(C), pages 255-268.
    11. Bucovetsky, Sam & Haufler, Andreas, 2008. "Tax competition when firms choose their organizational form: Should tax loopholes for multinationals be closed," Journal of International Economics, Elsevier, vol. 74(1), pages 188-201, January.
    12. Mijoč Ivo & Alić Martina Briš & Drvenkar Nataša, 2024. "What We Know So Far about Transfer Pricing: a Bibliometric Analysis," Zagreb International Review of Economics and Business, Sciendo, vol. 27(1), pages 253-282.
    13. Kristian Behrens & Susana Peralt & Pierre M. Picard, 2014. "Transfer Pricing Rules, OECD Guidelines, and Market Distortions," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 16(4), pages 650-680, August.
    14. Johannesen, Niels, 2010. "Imperfect tax competition for profits, asymmetric equilibrium and beneficial tax havens," Journal of International Economics, Elsevier, vol. 81(2), pages 253-264, July.
    15. Leonce Ndikumana, 2014. "International Tax Cooperation and Implications of Globalization," CDP Background Papers 024, United Nations, Department of Economics and Social Affairs.
    16. HINDRIKS, Jean & nishimura, YUKIHIRO, 2014. "International tax leadership among asymmetric countries," LIDAM Discussion Papers CORE 2014028, Université catholique de Louvain, Center for Operations Research and Econometrics (CORE).
    17. George R. Zodrow, 2019. "Capital Mobility and Capital Tax Competition," World Scientific Book Chapters, in: George R Zodrow (ed.), TAXATION IN THEORY AND PRACTICE Selected Essays of George R. Zodrow, chapter 18, pages 543-570, World Scientific Publishing Co. Pte. Ltd..
    18. Ruud Mooij & Li Liu, 2020. "At a Cost: The Real Effects of Transfer Pricing Regulations," IMF Economic Review, Palgrave Macmillan;International Monetary Fund, vol. 68(1), pages 268-306, March.
    19. repec:spo:wpmain:info:hdl:2441/3381 is not listed on IDEAS
    20. repec:hal:spmain:info:hdl:2441/3381 is not listed on IDEAS
    21. Sandrine Levasseur, 2002. "Investissements directs à l'étranger et stratégies des entreprises multinationales," Revue de l'OFCE, Presses de Sciences-Po, vol. 0(5), pages 103-152.
    22. Sven Stöwhase, 2005. "Asymmetric Capital Tax Competition with Profit Shifting," Journal of Economics, Springer, vol. 85(2), pages 175-196, August.
    23. Ioana NEACSU & Liliana FELEAGA, 2017. "Evolutions and tendencies regarding the Romanian transfer pricing legislation: is there a need for change?," The Audit Financiar journal, Chamber of Financial Auditors of Romania, vol. 15(145), pages 1-65, February.

    More about this item

    Keywords

    transfer pricing; arm’s length principle; affiliation relationships; double taxation of results; manipulation of results; transfer pricing documentation;
    All these keywords.

    JEL classification:

    • M40 - Business Administration and Business Economics; Marketing; Accounting; Personnel Economics - - Accounting - - - General

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:aud:audfin:v:134:y:2016:i:14:p:183. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Dumitru Valentin Florentin (email available below). General contact details of provider: http://revista.cafr.ro/ .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.