Transfer pricing remains an inevitable tool for MNCs to carry out intra-company transactions. From the literature, misuse of transfer pricing has been observed with respect to advertisement, marketing and promotion (AMP). This research paper attempts to demonstrate the instances wherein abuse of...

This paper aims at providing a comprehensive overview of existing literature on the topic of comparability adjustments. Based on existing literature the most commonly used adjustments can be categorized in two broad categories: “accounting and financial risks adjustments” and...

This paper elaborates on the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. It refers to how globalizing business processes trigger governance change on the nation state level regarding the identification...

This paper seeks to re-examine the formulary alternative to transfer pricing by inquiring whether partial integration of formulary concepts into current practices would offer a reasonable alternative to transfer pricing rules. We believe that the key to achieving an equitable and efficient...

This paper models strategic taxation policy of home and host governments when a multinational enterprise sets transfer prices on globally joint inputs such as research and development. Tax credit and deduction allowances, as well as no taxation of foreign-earned profits, result in identical...

The objective of this paper is to analyze the procedures used by multinational enterprises to distribute the income generated by its foreign subsidiaries, and how they allocate the taxes paid on this income through the fiscal jurisdiction in which they operate, from the institution based view....

Finding common ground between corporate tax compliance and enforcement appears difficult and expensive, judging by the current inventory of almost $200 billion in proposed IRS transfer pricing tax adjustments, and projections of as much as $100 billion or more in annual U.S. federal corporate...

Most papers on transfer pricing deal either with technical aspects of the topic or strategy. Research on ethical aspects of transfer pricing is almost totally absent from the business literature and is scantly covered in the ethics literature. The purpose of this paper is to fill that gap....

How and why does the firm size distribution differ across countries? Using two datasets covering more than 30 countries, this paper documents that several features of the firm size distribution are strongly associated with income per capita: the entrepreneurship rate and the fraction of small...