The main focus of this paper is on the international transfer pricing issues encountered by multinational enterprises (MNE) and the countries they do business in. This paper explores how the conflicting interests of MNEs and the countries they do business in affects each party's bottom line, tax...

This paper examines transfer pricing in general. First, three different approaches to transfer pricing options and their advantages and disadvantages are investigated. Based on the analysis, it is difficult to make recommendations on the best transfer pricing methods. Next, the international...

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...

In this article we introduce a stochastic model with a multinational company (MNC) that exploits tax avoidance practices. We focus on both transfer pricing (TP) and debt shifting (DS) activities and show how their optimal level is chosen by the shareholders. In addition, we perform an extensive...

One of the aims of the BEPS Action Plan is to reduce existing leeway for multinational enterprises to shift profits by exploiting transfer pricing rules. Profit allocation is meant to be aligned with “real activity” and “value creation.” This article is devoted to the question of whether...

This analysis refers to the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. APAs are a type of non-bureaucratic, cooperative governance that exists between the multinational corporate taxpayer and the...