The European Court of Justice has confirmed the compatibility of transfer pricing adjustments under the arm's length standard in its "SGI" judgment. In this decision, the ECJ has stated that transfer pricing control is justified as a means to fight "artificial arrangements" while commercially...

This paper is centred on the advanced pricing agreements (APAs). The increasing globalisation has created many challenges for multinational enterprises (MNEs) and among these are taxation and accounting related issues. Transfer pricing issues have become a major international taxation issue in...

This paper contrasts the recent European initiatives on regulating corporate groups with alternative approaches to the phenomenon. In doing so it pays particular regard to the German codified law on corporate groups as the polar opposite to the piecemeal approach favored by E.U. legislation. It...

The purpose of the present investigation is to provide a short overview of themain implications arising from carrying related parties transactions: accounting reporting(related party disclosures - IAS 24), auditing (audit procedures for related partytransactions), taxation (issues regarding the...

This paper analyzes transfer pricing incentives under a destination-based and an origin-based VAT system. While a switch to the origin-based VAT may moderate or reinforce the incentive for transfer pricing induced by income tax differentials, we show that in the case of the EU this switch tends...

This paper analyzes the effect of statutory tax rates on the location of Japanese capital in emerging countries. Considering the fact that the difference between Japan and foreign tax rates can engender transfer pricing manipulation to diminish tax liabilities, and that some firms are more able...

This paper analyzes effects of an equalization tax on the decisions of a multinational company. An equalization tax is an extra corporation tax on dividend distributions to ensure that the underlying profit of a dividend has borne a tax in the corporate sector equal to the imputation credit...

In this paper we show that the ability of multinational firms to manipulate transfer prices affects the tax sensitivity of foreign direct investment (FDI). We offer a model of international capital allocation where firms are heterogeneous in their ability to manipulate transfer prices. Perhaps...

This paper derives an appropriate standard price that can be used by the tax authorities of a country for auditing transfer prices in multinational firms (MNFs) for the purpose of social welfare maximization of the country. We assume that the corporate tax rate in the host country, where MNFs...

In this paper we show that the ability of multinational firms to manipulate transfer prices affects the tax sensitivity of foreign direct investment (FDI). We offer a model of international capital allocation where firms are heterogeneous in their ability to manipulate transfer prices. Perhaps...