scholarly journals Comparative overview of transfer pricing tax regulation in the world

2019 ◽  
pp. 111-127
Author(s):  
Ljiljana Tanasić
Author(s):  
Volodymyr Metelytsya

The regulation of the professional activities of accountants either promotes business development, the migration of financial and human capital, or complicates this process. Many firms with global interests may already be feeling the burden of complex and ever-changing regulations issued at domestic and international level. It is expected that some regions of the world are likely to face far more regulation of financial activities, including accounting. The purpose of the article is to analyze the latest changes in the regulation of the professional activity of accountants caused by the transformations of the global economic system, as well as to identify and assess the challenges that accountants around the world will face in the coming years. The tendencies in the field of regulation of professional activity of accountants in Europe, USA, Australia, Asia were revealed, and the factors (reasons) of their development were determined. In particular, in Europe, there are growing calls for more regulation in finance and “fairness” in tax especially when it comes to taxing digital corporations, whereas in the US, things are moving in the opposite direction, with less regulation to encourage growth. Across the Asian region, banking and corporate regulation is becoming more stringent and the expectations of revenue authorities around issues such as transfer pricing documentation are increasing. It has been determined that the existence of accounting standards and rules as such does not guarantee reliable and appropriate financial indicators, and therefore the role and importance of professional ethics increases. Three key areas of change and challenges for the accounting profession that will take place in the coming years were assessed. It has been proven that the goal of strengthening regulation around the world is to solve socio-economic and environmental problems. It is important for accountants to realize that such events should develop motivation not to manipulate numbers, as well as ensure the introduction of a system of fair taxation and elimination of abuses by the subjects of the digital economy. So, all over the world there is a real need to educate accountants on the changing global regulatory framework.


Author(s):  
Habip Demirhan

The globalization movements that had emerged in the last century have not only influenced the world's social, political, and cultural structure, but also have influenced its economic structure as well. The globalization of the world economy makes locations and economic units between countries or regions interdependent on one another. The primary driving forces of this process include technological change and multinational enterprises. Thus, intercompany transactions are important for multinational enterprises. In recent years, discussions regarding the applicability of blockchain technology, or more commonly referred to as crypto coins, for the public sector have emerged. This study therefore attempts to explain the applicability of blockchain technology in relation to transfer pricing, and it clarifies (1) how blockchain technology represents a new approach to transfer pricing, (2) how blockchain technology reduces transfer pricing evasion, and (3) how blockchain technology increases both transparency and accountability.


2021 ◽  
Vol 116 (3) ◽  
pp. 36-51
Author(s):  
KUDYRKO Liudmyla ◽  
ANTIKHOVYCH Volodymyr

Background. Along with increasing share of ICT services in global production and trade, additional possibilities have been provided for MNCs to minimize taxes through transfer pricing mechanisms and controlled international transactions for intangible assets. These processes lead to leaching of financial and investment resources from countries in conditions of extremely high demand for their accumulation. The latest regulatory practices of state governments demonstrate the renaissance of economic nationalism in the form of intensified interstate fiscal competition. The aim of this article is to assess the impact of digitalization of the world economy onto the possibilities of fiscal optimization of the MNC and analysis of the latest regulatory practices of state governments through direction of interstate fiscal competition and fiscal «wars». Materials and methods. The information base of the study was scientific foreign and domestic scholars’ publications; data from analytical companies and statistical services; international organizations. The approaches of normative and positive economics, elements of institutional analysis and Case method were used. Results. The article identifies the impact of digitalization of global trade and production on the processes of optimizing fiscal payments by international companies. Systematization and estimation of certain international regulatory practices on digital trade taxation have been carried out and their content has been identified as new fiscal «wars». Conclusion. Recent fiscal «wars»as a factor influencing the world economy should be recognized as a negative phenomenon based on multifactorial differences between countries caused by economic, political, organizational and diplomatic obstacles.Despite targeted steps, there are currently no preconditions for the accession of all participants in transnational trade, including digital, as a general regulatory act to establish uniform rules for its taxation.


2021 ◽  
Vol 23 (5) ◽  
pp. 100-108
Author(s):  
Anastasia Nevskaya ◽  

The article examines the combination of the Netherlands’ departure from the role of a transit jurisdiction for capital from all over the world and their struggle to attract the headquarters of multinational companies, including those migrating from the UK due to Brexit. It is shown that these processes are due to both fundamental reasons and the current need of countries for tax refunds to replenish their budgets to cover the consequences of the pandemic crisis. The author comes to the conclusion that the restructuring of the rules of international tax regulation which is going on now, may cause clashes of countries’ interests and strategies, which is illustrated by the example of the breakdown of the Agreement on the avoidance of double taxation between Russia and the Netherlands.


Author(s):  
Srđan Lalić ◽  
Brankica Dragičević

About 70 % of today's world tradetakes place between related companies. Transactionsbetween them are called assignment or transfer, andthe prices at which the group of related companiesaccounted value of the purchase and sale of financialresults, are called transfer pricing. The main aim ofthis paper is to determine the impact that transferpricing has on the creation of international tax issues.Transfer prices between related parties maysubstantially differ from the prices created for thesame or similar transactions between unrelatedindividuals in a free market. Transfer prices are animportant tax issue which is characterized byincreasing complexity and level of commitment of taxauthorities around the world on this issue.


Author(s):  
Simplice A. Asongu

A recent publication by the World Bank on Millennium Development Goals (MDGs) has established that extreme poverty has been decreasing in all regions of the world with the exception of sub-Saharan Africa (SSA), in spite of over two decades of growth resurgence. This chapter explores the role of transfer mispricing in SSA's extreme poverty tragedy. The analytical structure entails: (1) emphasis of rational asymmetric development as the dark side of transfer pricing; (2) linkages between financial reporting, international financial reporting standards (IFRS), transfer pricing and poverty; (3) evidence that the recent growth resurgence in African countries has been driven substantially by resource-rich countries which are experiencing high levels of exclusive growth and extreme poverty; (4) the practice of transfer mispricing by multinationals operating in resource-rich countries of SSA and (5) a Zambian case study of extreme poverty and transfer mispricing schemes by Glencore in the copper industry. While transfer mispricing is contributing to diminishing African growth, available evidence shows that the component of growth that is not captured by transfer mispricing does not trickle down to the poor because the African elite is also animated by practices of rational asymmetric development. Policy implications for the fight against extreme poverty are discussed.


2021 ◽  
Vol 116 (3) ◽  
pp. 85-97
Author(s):  
HLADIY Iryna

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.


Pro Futuro ◽  
2020 ◽  
Vol 9 (3) ◽  
Author(s):  
Tamás Zoltán Wágner

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.


Sign in / Sign up

Export Citation Format

Share Document