scholarly journals The role of a reference yield fitting technique in the fund transfer pricing mechanism

2019 ◽  
Vol 63 (2) ◽  
pp. 16-24
Author(s):  
Ewa Dziwok
Keyword(s):  
Transfer Pricing ◽  
Pricing Mechanism

scholarly journals The influence of international offshore jurisdictions on the pricing strategy

VUZF Review ◽  
2021 ◽  
Vol 6 (4) ◽  
pp. 79-90
Author(s):  
Оlena Chukurna ◽  
Larysa Radkevych ◽  
Liliya Rudyk
Keyword(s):  
Transfer Pricing ◽  
Pricing Strategy ◽  
Pricing Mechanism ◽  
Pricing Process ◽  
Transfer Prices ◽  
National Economies ◽  
The Impact ◽  
The Relationship ◽  
A Company

The article analyzes the causes of offshore jurisdictions and identifies the effects of offshore on national economies. An analysis of the implementation of export-import operations carried out by offshore companies in order to influence the pricing process. The pricing mechanism with affiliates within offshore jurisdictions was presented. It was substantiated the role of offshore banks in the implementation of the pricing mechanism. It was presented the pricing mechanisms within offshore jurisdictions. It has been made an analysis of the impact of transfer pricing within offshore jurisdictions. It was substantiated the economic mechanism of pricing. The international experience of regulation of offshore jurisdictions and the system of controlling the operations of affiliates was analyzed. It was substantiated the mechanisms of functioning of offshore zones and companies operating in offshore jurisdictions. The relationship between agreements concluded within offshore jurisdictions in the following areas is established and substantiated: the agreement is concluded between two independent companies in case of underpricing; the agreement is concluded between the companies connected with the capital relations (affiliated companies) at understatement of the price; agreements between two independent companies in case of overpricing; agreements between affiliated companies in case of overpricing. It was justified the use of the transfer pricing mechanism within offshore jurisdictions. Transfer prices allow you to withdraw capital from the country, as well as hide the profits of companies from taxation. The following ways of minimizing taxation are systematized: registration of a company that concentrates profits in a jurisdiction with lower taxation; concentration of profits in companies that are unprofitable according to management accounting; the use of front companies as sales companies in which profits are concentrated; non-payment of taxes as a result of illegal liquidation of the enterprise - the taxpayer, where the profit is concentrated. The basis of tax minimization is the use in the transaction of a price that deviates from the market.

Prices: Market Mechanism and State Regulation

2011 ◽  
pp. 40-50
Author(s):  
E. Glazova ◽  
M. Stepanova
Keyword(s):  
State Regulation ◽  
Market Mechanism ◽  
Competitive Environment ◽  
Market Pricing ◽  
Pricing Mechanism

The article examines the role of state regulation of prices – indirect or direct – with the aim to create a competitive environment (if it is absent) or to strengthen competition with its imperfections in order to eliminate those violations of market pricing mechanism which the market itself cannot resolve.

scholarly journals Does Transfer Pricing Moderate the Effect of Deferred Tax Assets and Deferred Tax Expenses on Accrual Earnings Management of Firms in Indonesia?

2021 ◽  
Vol 6 (3) ◽  
pp. 97-103
Author(s):  
Nera Marinda Machdar ◽  
Dade Nurdiniah
Keyword(s):  
Earnings Management ◽  
Transfer Pricing ◽  
Manufacturing Companies ◽  
Moderator Variable ◽  
Policy Makers ◽  
Deferred Tax Assets ◽  
Management Actions ◽  
Deferred Tax ◽  
Accounting Policy

The purpose of this study is to analyze (a) the effect of deferred tax assets on accrual earnings management; (b) the effect of deferred tax expenses on accrual earnings management; (c) the role of transfer pricing as a moderator variable to strengthen the effect of deferred tax assets on accrual earnings management; and (d) the role of transfer pricing as a moderator variable to strengthen the effect of deferred tax expenses on accrual earnings management. The samples consist of 160 manufacturing companies listed in Indonesia Stock Exchange (IDX). The study utilizes the financial statements from 2012 to 2018. This study presents that (a) deferred tax assets influence accrual earnings management; b) deferred tax expenses affect accrual earnings management; c) transfer pricing does not strengthen the effect of deferred tax assets on accrual earnings management; and d) transfer pricing does not strengthen the effect of deferred tax expenses on accrual earnings management. This study contributes to accounting studies, tax authorities and regulators, and accounting policy makers. Firstly, this research contributes to the development of accounting studies on the role of transfer pricing as a moderator of the effect of deferred tax assets and deferred tax liabilities on earnings management. Secondly, the results of this study can make a consideration for tax authorities and regulators in addressing company management actions to minimize the amount of tax paid by utilizing policies according to PSAK. It is worth considering how to sanction companies that deliberately reduce the amount of tax that should be paid. It is necessary to conduct tax investigation by the Directorate General of taxes on companies that are indicated to have practiced accrual earnings management with the aim of reducing the tax burden. Thirdly, accounting policy makers need to consider how management reduces the tax that should be paid through accounting policies that are allowed under PSAK and transfer pricing mechanism.

scholarly journals Recharacterizing Corruption to Encompass Illicit Financial Flows

AJIL Unbound ◽  
2019 ◽  
Vol 113 ◽  
pp. 336-340 ◽  
Author(s):  
James Thuo Gathii
Keyword(s):  
Multinational Corporations ◽  
Transfer Pricing ◽  
Public Officials ◽  
Financial Flows ◽  
Development Agenda ◽  
Role Of The State ◽  
Illicit Financial Flows ◽  
Definition Of ◽  
Private Actors

Anticorruption treaties generally define corruption as the abuse of entrusted power for private gain. As such, global anticorruption efforts primarily target transactions involving the bribery of governmental officials. The definition excludes transactions in which multinational corporations deprive developing states of revenue by failing to pay taxes and other monies due. Yet such transactions are equally injurious to the development agenda of poor states. This essay argues that corruption should be redefined to encompass illicit financial flows, a term used by a growing network of tax and economic justice groups to refer to money that is “illegally earned, transferred or used.” Transactions such as trade misinvoicing, base-erosion, and abusive transfer pricing to illegally earn additional income undermine the ability of poor states to raise revenue for development. Expanding the definition of corruption would create a more realistic picture of the role of corporate actors and their involvement in corrupt and illicit dealings. It would also bring equivalency to the treatment of corporate actors and public officials. By focusing on illicit dealings involving corporate actors, this essay challenges the partial definition of corruption adopted in the heyday of the Washington Consensus, when skepticism about the role of the state, rather than of private actors, prevailed.

The Role of Informal Controls and a Bargaining Opponent's Emotions on Transfer Pricing Judgments

2016 ◽  
Vol 34 (1) ◽  
pp. 427-454 ◽  
Author(s):  
Sudip Bhattacharjee ◽  
Kimberly K. Moreno
Keyword(s):  
Transfer Pricing ◽  
Informal Controls

scholarly journals The moderating role of audit quality and firm size in the effect of corporate governance on related party transactions: Evidence from Indonesia

2021 ◽  
Vol 18 (4) ◽  
pp. 166-176
Author(s):  
Perdana Wahyu Santosa ◽  
Sovi Ismawati Rahayu ◽  
Zainal Zawir Simon ◽  
Martua Eliakim Tambunan
Keyword(s):  
Corporate Governance ◽  
Firm Size ◽  
Firm Value ◽  
Information Quality ◽  
Audit Quality ◽  
Stock Exchange ◽  
Transfer Pricing ◽  
Complete Information ◽  
Related Party Transactions

This study aims to analyze the essential corporate governance determinants of related party transactions (RPTs) in Indonesia. Based on a hand-collected sample of three business groups of small, medium, and large-cap publicly listed firms on the Indonesia Stock Exchange (IDX) for 2013–2019, panel regression results find that foreign shareholders and firm size have a significant effect, at –2.402 and 0.248, respectively. The moderating model of audit quality shows that domestic shareholders, foreign shareholders, and firm size are significantly negatively associated, with –5.627 and –5.958 at 5%, respectively. Similar results show that foreign shareholders and independent commissioners significantly negatively affect related party transactions at –2.864 and –1.845, moderating the firm size at 10% and 5%, respectively. The moderation of regression results also indicates that audit quality and firm size tend to strengthen negative effects on the association between related party transactions and corporate governance. The moderation interaction confirms that audit quality will determine that domestic and foreign shareholders tend to increase the number of affiliate transactions. The interaction of complete information quality will force domestic and foreign shareholders to increase the role of affiliate transactions in creating firm value. The larger size of the firm, which is owned by foreign shareholders, will increase the intensity of cross-border related party transactions through the combined effects in the context of internationalization with a tendency of expropriation and transfer pricing practices, which can reduce government tax incomes. Acknowledgment We are grateful to the Ministry of Education, Culture, Research and Technology, Indonesia, for research grant No. 163/E4.1/AK.04.PT/2021, as well as the editor of the Investment Management and Financial Innovations journal, peer reviewers, and some colleagues for their suggestions, criticism and comments that significantly improved this paper.

scholarly journals The Role of Transfer-Pricing Schemes in Coordinated Supply Chains

2010 ◽  
Vol 25 (3) ◽  
pp. 375-404 ◽  
Author(s):  
Kashi R. Balachandran ◽  
Shu-hsing Li ◽  
Taychang Wang ◽  
Hsiao-wen Wang
Keyword(s):  
Supply Chains ◽  
Transfer Pricing ◽  
Pricing Schemes
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