scholarly journals TRANSFER PRICING OF TRANSNATIONAL CORPORATIONS

2021 ◽  
Vol 116 (3) ◽  
pp. 85-97
Author(s):  
HLADIY Iryna
Keyword(s):  
World Economy ◽  
System Analysis ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Transnational Corporations ◽  
Sources Of Information ◽  
Advantages And Disadvantages ◽  
Arm’S Length Principle ◽  
Pricing System ◽  
The World

Background. In the context of globalization, transnational corporations have turned into highly concentrated points of the world economy and the principal markets for goods and services. It is under such conditions that a comprehensive research of the pricing system within the framework of their activities is relevant. Analysis of recent research and publications has revealed that the process of setting prices for products within their activities in different countries and the development of innovations in domestic legislation require in-depth study. The aim of the article was to study possible transfer pricing systems for TNCs in order to eliminate risks when calculating the exact cost of products and avoid possible situations of non-payment of due taxes. Materials and methods. A set of general scientific methods of cognition is applied: inductive, deductive, system analysis, theoretical generalization, formal-logical, analysis and synthesis. Results. The transfer pricing system is becoming the key direction in the process of planning and profit maximization. The methods of setting the transfer price are legally enshrined in the current Tax Code of Ukraine. However, the use of these methods is a top priority for checking compliance with the «arm’s length»principle. It is determined that in order to comply with this principle, it is necessary to compare controlled and uncontrolled transactions, based on the criterion of tax benefits, as well as to analyse all the advantages and disadvantages that they create. Conclusion. The issue of proper transfer pricing plays a leading role in the export or import of goods. Particular attention should be paid to the sources of information indicated by taxpayers and used in order to ensure compliance with the requirements for justification in the documentation on transfer pricing compliance with the conditions of controlled transactions with the arm’s length principle. Prospects for further research are to provide practical recommendations for compliance of the legal and regulatory framework for transfer pricing with the requirements of the world economy in the direction of preventing the implementation of tax avoidance schemes.

scholarly journals Detrimental effects of tax havens and the case of the Dutch tax system

Pro Futuro ◽  
2020 ◽  
Vol 9 (3) ◽  
Author(s):  
Tamás Zoltán Wágner
Keyword(s):  
World Economy ◽  
Negative Impact ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Tax Rates ◽  
The European Union ◽  
Tax System ◽  
Tax Havens ◽  
The World ◽  
State Budgets

Nowadays, multinationals have become so strong that they can easily compete with states. Consequently, they have the opportunity to develop several tax minimalization strategies such as transfer pricing, inversion, hybrid entities etc. All these have a negative impact on the world economy and state budgets. Despite detrimental effects, certain countries try to cooperate with multinationals by transforming themselves into tax havens. In this framework, they provide multinationals with various kinds of tax advantages such as deductions, low tax rates and preferential tax rulings (“sweetheart deals”). Although, the general attitude towards tax avoidance in the European Union is negative, particular member states’ tax systems display several characteristics of tax havens. In this regard, it should be noted that multinationals regularly use the loopholes and other advantages of the Dutch tax system to minimise their tax liability. The following study – after a brief view to the characteristics of tax havens– will illustrate these options by highlighting the fact that the country – despite the denial of the respective governments – still displays several characteristics of - tax havens.

Globalization of Economy: qualis es et quo vadis?

2011 ◽  
pp. 16-24
Author(s):  
V. Pan'kov
Keyword(s):  
World Economy ◽  
Historical Perspective ◽  
Transnational Corporations ◽  
Main Subject ◽  
Short Term ◽  
Positive Effects ◽  
Current State ◽  
The World ◽  
Quo Vadis ◽  
State Of Affairs

In a long historical perspective, the globalization of the economy is, no doubt, the future of the mankind. However, we should not overlook the contradiction that has dramatically intensified as a result of the 2008-2009 recession. This is the contradiction between globalization as an objective process with mostly positive effects and its model that is being implemented today (namely, the policy of globalization). Furthermore, we can propose a number of important arguments in favor of a statement that at the current state of affairs the globalization has exhausted itself. Nobody can exclude a short-term braking down of the globalization progress nor even a U-turn, albeit temporary, to a de-globalization. Under unfavorable circumstances such a reverse movement can cover the entire period up to 2020. The author states that transnational corporations are the main subject of the world economy which will the most actively oppose such a development.

Challenges of Monitoring Tax Compliance by Multinational Firms: Evidence from Chile

2019 ◽  
Vol 109 ◽  
pp. 500-505
Author(s):  
Sebastián Bustos ◽  
Dina Pomeranz ◽  
José Vila-Belda ◽  
Gabriel Zucman
Keyword(s):  
Multinational Firms ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Tax Compliance ◽  
Tax Rates ◽  
Profit Shifting ◽  
Effective Tax Rates ◽  
Arm’S Length Principle ◽  
Debt Shifting

This paper reviews common challenges of taxing multinational firms, using Chile as a case study. We briefly describe key international tax avoidance methods: profit shifting to low-tax jurisdictions through transfer pricing and debt shifting. We discuss the prevalent policy to tax multinationals--the arm's length principle--and alternative proposals using apportionment formulas. Novel data from Chile show that multinationals make up a large share of GDP but report lower profit and effective tax rates than local firms. In 2011, Chile implemented a reform following OECD guidelines to enforce the arm's length principle. We discuss potential effects on tax collection and welfare.

World economy and international economic relations

2020 ◽  
Author(s):  
Ol'ga Baburina
Keyword(s):  
International Economic ◽  
World Economy ◽  
System Analysis ◽  
Point Of View ◽  
Modern World ◽  
Federal State ◽  
Economic Relations ◽  
International Economic Relations ◽  
The World ◽  
State Educational

The main provisions of the theory of the world economy and international economic relations are presented. The strengthening of the integrity of the world economy is justified. The most important indicators from the point of view of system analysis are given. The concepts, concepts and dynamics of development of key forms of international economic relations are revealed. The construction of the balance of payments of various countries is analyzed. In the proposed publication, to control the level of mastering the discipline on each topic, tests, topics of reports and abstracts are given, practice-oriented tasks are developed based on objective statistical data of recent years. Meets the requirements of the Federal state educational standards of higher education of the latest generation. For bachelors studying in the field of Economics, it can be useful for teachers who lead the disciplines "World economy", "World economy and international economic relations", as well as for anyone interested in the processes taking place in the modern world economic system and the role of Russia in it.

scholarly journals FEATURES OF THE DEVELOPMENT OF TRANSNATIONAL CORPORATIONS, THEIR ROLE IN THE WORLD ECONOMY

2021 ◽  
Vol 6 (2(30)) ◽  
pp. 14-20
Author(s):  
V. N. Borobov
Keyword(s):  
World Economy ◽  
Statistical Data ◽  
Transnational Corporations ◽  
Multinational Companies ◽  
Modern World ◽  
Scientific Article ◽  
Development Indicators ◽  
The World ◽  
Further Development

The scientific article examines the nature and role of TNCs in the modern world economy. The stages of development of multinational companies with a detailed description are described in some detail. Statistical data on the development indicators of TNCs over the years are presented. Indicators of the increasing role of foreign branches of TNCs in the overall results of their operation. Activities are proposed on the strategic priorities of TNC profit generation and further development.

scholarly journals Transfer Pricing As A Vehicle In Corporate Tax Avoidance

2016 ◽  
Vol 33 (1) ◽  
pp. 9-16 ◽  
Author(s):  
Joel Barker ◽  
Kwadwo Asare ◽  
Sharon Brickman
Keyword(s):  
Transfer Pricing ◽  
Tax Avoidance ◽  
Tax Rates ◽  
Corporate Tax ◽  
Internal Revenue ◽  
Tax Reduction ◽  
Arm’S Length Principle ◽  
Corporate Tax Rates ◽  
Foreign Affiliates ◽  
Regulatory Bodies

Using transfer pricing, U.S. Corporations are able to transfer revenues to foreign affiliates with a lower corporate tax rates.  The Internal Revenue Code requires intercompany transactions to comply with the “Arm’s Length Principle” in order to prevent tax avoidance.   We describe and use elaborate examples to explain how US companies exploit flexibility in the tax code to employ transfer pricing and related tax reduction and avoidance methods. We discuss recent responses by regulatory bodies.

MECHANISMS OF STRUCTURAL REFORMING OF CHINA’ ECONOMY IN THE CONTEXT OF DEVELOPMENT OF THE TRADE CONFLICT WITH THE USA

2019 ◽  
pp. 31-44
Author(s):  
Evgeniy N. Smirnov
Keyword(s):  
Financial Crisis ◽  
World Economy ◽  
System Analysis ◽  
Global Financial Crisis ◽  
Raw Materials ◽  
Problem Analysis ◽  
The World ◽  
Analysis And Synthesis ◽  
The Usa ◽  
Relationship Of

The world economy recovers from global financial crisis slowly and unevenly that calls a question about efficiency and advantage of economic globalization for the countries of the world. Developing countries recovered from global financial crisis of 2008–2009 comparative quickly, and it was promoted in many respects by the high prices of raw materials and low levels of debt of these countries. NowChinatakes leader positions in the international capital flow and world trade. Globalization had significant effect on scales of the involvement of the country into world economic communications that became one of the reasons of overheating of national economy. The economy ofChina, besides the increasing overheating potential, begins to be under pressure from the trade conflict initiated by theUSA. In these conditions problems of structural reforming ofChina’ economy, on that depend competitive positions of the country in the world economy depend, become aggravated. In modern Sinology, the problems of trade conflicts between countries are studied very fragmentally. Approaches of the author are based on the results previously obtained by Russian scientists Y. M. Galenovich, A. P. Mozias, M. L. Titarenko, and theoretical developments of leading research centers. Historical approach, comparative, system analysis and synthesis, prognostic and problem analysis were used as instrumental scientific methods in the research presented in the article. The author's ideas are based on the hypothesis of the relationship of «overheating», appearing in the economies with the growth of economic contradictions and conflicts between them.

On the role of transnational corporations in modern integration and globalization processes

2019 ◽  
pp. 97-106
Author(s):  
P.Yu. Baryshnikov
Keyword(s):  
World Economy ◽  
Transnational Corporations ◽  
Negative Consequences ◽  
Host Countries ◽  
The World ◽  
New Type ◽  
The One ◽  
The Impact ◽  
The Relationship

The subject of the author's research is the development of transnational corporations (TNCs) as an organic component of modern international economic integration and globalization processes. The concept and features of TNCs are characterized. A brief historical overview of the formation and development of corporate transnationalism is proposed. Statistics on the largest TNCs are presented and analyzed. On the one hand, positive aspects of the impact of TNCs on the development of the world economy and its national components were identified, and on the other hand, the negative consequences of the expansion of these corporations for both host countries and home countries of TNCs. The relationship between TNCs and sovereign States is considered in many aspects. Thus, based on the analysis of the instruments of influence of the companies under consideration on the normative activities of the States, a shift from the interstate to the corporate legal field was recorded. One of the subjects of the article is mega regional trade agreements of a new type as a factor of increasing the contradictory impact of TNCs on the development of the world economy and its national components.

Place of transfer pricing in the tax system

2021 ◽  
Author(s):  
Artem Kotenko ◽  
Mykola Mishyn
Keyword(s):  
System Analysis ◽  
Transfer Pricing ◽  
Legal Regulation ◽  
Main Body ◽  
Tax System ◽  
Local Taxes ◽  
Arm’S Length Principle ◽  
Definition Of ◽  
Problem Setting ◽  
Broad Approach

Problem setting. The approach proposed by the legislator to the definition of the tax system as a set of national and local taxes and fees in the procedure established by the TC of Ukraine, constitutes the tax system of Ukraine (para. 6.3 of Article 6 of the TC of Ukraine), raises the question of the place of transfer pricing in the tax system. If you approach the tax system as a set of taxes and fees, the transfer pricing is actually excluded from the tax system. Analysis of recent researches and publications. Among the scientists involved in the research of the tax system, it is possible to distinguish M. Kucheryavenko, D. Getmantsev, N. Pryshva, O. Barin and others. Some problems of legal regulation of transfer pricing were dealt with by M. Mishin, M. Bondarenko, K. Broyakov and others. The target of the research is to analyze and determine the place of transfer pricing in the tax system. Article’s main body. The article is devoted to determining the place of transfer pricing in the tax system. We propose our own view on the tax system. It is stated that a broad approach to understanding the tax system excludes contradictions laid down in para. 6.3 of Article 6 of the TC of Ukraine. Conclusions and prospects for the development. Transfer pricing involves the application of special methods for determining the compliance of the conditions of the controlled transaction with a certain criterion – the “arm’s length” principle, drawing up and submitting reports, exercising control and bringing to responsibility for violation of transfer pricing requirements. The legislative approach to the content of the tax system as an aggregate of taxes and fees actually excludes transfer pricing from the tax system. Instead, our proposed broad approach eliminates such contradiction.

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