Search

Copyright of Contemporary Accounting Research is the property of Canadian Academic Accounting Association and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Contemporary Accounting Research is the property of Canadian Academic Accounting Association and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Die Unternehmensbesteuerung (Ubg) is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Realizing the multifunctional value of farmland is essential for regulating the pricing of farmland transfers and stabilizing the rural land market. However, in China, the mismatch between supply and demand leads to improper resource allocation, weakens the explicit value of farmland, and causes unreasonable transfer pricing mechanisms that threaten agricultural production and food security. This study develops an analytical framework to examine the relationship between farmland multifunction and transfer pricing from a supply–demand perspective. An evaluation index system is constructed, considering the physical, value, and material quantities. This study uses the matching index method and bivariate spatial autocorrelation to analyze the supply–demand match of farmland multifunction from 2014 to 2021 and its relationship with transfer prices. Additionally, management methods and strategies for dynamic zoning-based pricing under multifunctional matching trade-offs are proposed. The results show that: (1) There is significant heterogeneity in the supply and demand matching degree of different farmland functions in both space and time. The production and ecological functions of farmland are oversupplied, while the living functions are undersupplied. (2) Different spatial autocorrelation relationships exist between the degree of supply and demand matching of farmland functions and farmland transfer prices. Specifically, the supply and demand matching degrees of the production and living functions show a significant negative spatial correlation with farmland transfer prices. In contrast, the ecological function shows a significant positive spatial correlation with farmland transfer prices, which are continuously strengthening over time. (3) Based on the supply and demand matching situation of different farmland functions and the spatial autocorrelation of farmland transfer prices, nine types of regions are delineated for farmland functions. Among them, the surplus-coordinated development areas have the most cities, accounting for about 40%, with a wide distribution range. This study proposes zoning-based pricing instruments and management strategies. This research provides valuable insights for developing countries seeking to alleviate conflicts in multifunctional land use, enhance the sustainable protection of land resources, and improve land resource assessment frameworks. [ABSTRACT FROM AUTHOR]

Copyright of Die Unternehmensbesteuerung (Ubg) is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Jurnal Ekonomi Manajemen Sistem Informasi (JEMSI) is the property of Dinasti Publisher and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Professional football clubs invest vast amounts of money in the recruitment of players. This article presents the latest advances in statistical modeling of the factors that market actors take into consideration to determine the transfer prices of professional football players. It extends to a global scale the econometric approach previously developed by the authors to evaluate the transfer prices of players under contract with clubs from the five major European leagues. The statistical technique used to build the model is multiple linear regression (MLR), with fees paid by clubs as an independent variable. The sample comprises over 8000 transactions of players transferred for money from clubs worldwide during the period stretching from July 2014 to March 2024. This paper shows that a statistical model can explain up to 85% of the differences in the transfer fees paid for players. Despite the specific cases and other possible distortions mentioned in the discussion, the use of a statistical model to determine player transfer prices is thus highly relevant on a global scale. [ABSTRACT FROM AUTHOR]

This study analyzes a model in which intellectual property (IP) that generates uncertain future cash flows is sold by a U.S. parent to a foreign subsidiary. The parent has private, imperfect information regarding the value of the IP. The study compares the firm's expected tax and penalty payments under the commensurate with income (CWI) standard to the payments under the fair value method, in which the transfer price is the expected value of the IP using all the facts publicly available after the value is realized. It compares payments under both methods to the payments using the fair private price, which is the value of the IP on the date of sale given the parent's private information. Expected tax and penalty payments using the fair private price are strictly less than expected payments under the CWI standard and are strictly greater than expected payments under the fair value method. [ABSTRACT FROM AUTHOR]

The "Belt and Road Initiative" (BRI) drives international trade more and more frequently, making exchange rates and taxes unavoidable issues for multi-national companies. Thus, exchange risk uncertainty and tax saving planning should be considered in the operational decisions of a multi-national supply chain. This paper constructs a Stackelberg game model with four composite modes to explore the risk-taking and hedging strategy of retailers with reference-dependent psychology. The results show that: (1) exchange rate risk is transmitted through all subjects under the cost-plus transfer pricing strategy, while it is transmitted only between headquarters and retailers under the resale-price transfer pricing strategy. (2) No matter which subject bears the exchange rate risk, the motivation is stronger under the resale-price transfer pricing strategy. (3) The effect of futures hedging exchange rate risk is influenced by retailer reference-dependent psychology. When the reference dependence coefficient is low, and the risk of positive exchange rate fluctuations is too high, the retailer chooses to hedge its exchange rate risk. At this time, the transfer pricing strategy should shift to cost-plus, and the exchange rate fluctuation range that each entity can afford is larger than before hedging. [ABSTRACT FROM AUTHOR]

The Corruption Eradication Commission (KPK) sniffed out potential tax evasion through a transfer pricing scheme on alleged illegal nickel ore export practices to China. KPK Deputy for Prevention and Monitoring Pahala Nainggolan said that his agency is currently reviewing if there are weaknesses in the nickel governance system. The system in question is the Coal Mineral System or Simbara, which was launched in March 2022. The population of this study is mining sector manufacturing companies listed on the Indonesia Stock Exchange (IDX) from the period 2020 -- 2023. Determination of samples in this study using the purposive sampling method. The number of samples used was 18 companies with 72 research units. The source of data in this study is taken from the company's published annual report. Testing in this study using E-Views 12 software. The results of the study based on the panel data regression analysis test showed that debt convenant and intangible assets had an effect on transfer pricing, while the size of the company and the bonus mechanism did not affect transfer pricing. Tax minimization is able to moderate the relationship between company size, debt convenant, intangible assets, and bonus mechanisms for transfer pricing. [ABSTRACT FROM AUTHOR]

The purpose of this study was to obtain empirical evidence regarding the variables that may affect a company's decision of employing transfer pricing along with how that choice may affect tax avoidance. The variables that are used consist of the bonus mechanism, debt convenant, and tunneling incentive. The study used a two-stage regression analysis to analyze its hypotheses. 12 multinational manufacturing corporations listed between 2019 and 2021 on the Indonesia Stock Exchange represent the research sample. The purposive technique was the method used for selecting the research sample. The findings proved that the tunneling incentive has a negative impact on the decision of transfer pricing. This indicates the decision to utilize transfer pricing will be fewer depending on the percentage of foreign ownership in the business. In meanwhile, transfer pricing decisions are unaffected by bonus mechanism and debt covenants. Additionally, the findings demonstrate that tax evasion is unaffected by transfer pricing. This outcome demonstrates that there are still alternative strategies for avoiding taxes; transfer pricing has not become a significant one. The results of this study cannot be applied to other sectors within the company because it solely examines multinational manufacturing companies. Future research can use different variables or different measurements to get better results because not all of the variables used have an impact on transfer pricing or tax avoidance. The study's findings may be useful as a framework for other researchers looking into related subjects, and the results can also provide parties responsible for Indonesian taxation with more information to help them develop regulations related to transfer pricing and tax avoidance. [ABSTRACT FROM AUTHOR]

Tax avoidance, often driven by managerial discretion, remains a critical issue in corporate governance due to its implications for financial transparency and regulatory compliance. This study investigates how Transfer Pricing, Thin Capitalization, Leverage, and CSR Disclosure – strategies employed by managers – affect Tax Avoidance and examines the mediating role of Financial Reporting Aggressiveness. Grounded in agency theory, the study analyzes data from 20 firms listed on the Indonesian Stock Exchange from 2019 to 2023 using PLS-SEM. The findings reveal that Transfer Pricing (β = 0.062, p = 0.002), Leverage (β = 0.046, p < 0.001), and CSR Disclosure (β = 0.061, p < 0.001) significantly increase Tax Avoidance, with Financial Reporting Aggressiveness acting as a mediator. However, Thin Capitalization does not significantly influence Tax Avoidance (β = 0.028, p = 0.422). These results suggest that managers exploit these mechanisms to minimize tax burdens, often at the cost of long-term shareholder interests. The study calls for stronger corporate governance and stricter oversight of CSR reporting and financial transparency to mitigate such practices.

This article tackles the sensible and complex problem of international taxation. The main objective of the paper is to create a comprehensive fiscal space, especially at the European level, in the direct taxation domain. The main scope of the research is to identify, evaluate, and assess the main pillars and features of this fiscal space. The research methodology is based both on theoretical analysis of double taxation and transfer pricing issues, but also on practical aspects of several specific case laws. The conclusions of the article highlight the further improvement and development of the arm's length principle structure, improving double taxation multilateral conventions, recalibrating the mutual agreement procedure, and strengthening the tax authorities' international cooperation techniques and tactics. [ABSTRACT FROM AUTHOR]

Copyright of Contemporary Accounting Research is the property of Canadian Academic Accounting Association and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

The article analyzes the historical stages of the development of the international taxation system, paying special attention to the role of transfer pricing. The evolution of rules, tools, and methods of combating aggressive tax planning, in particular transfer pricing, is considered. The analysis of changes in the approaches to erosion of the tax base and profit shifting by transnational corporations and the corresponding reactions of international organizations and national tax authorities to the prevention of transfer pricing has been carried out. The prerequisites for the emergence and effectiveness of modern approaches in combating transfer pricing, including the OERS project on the erosion of the tax base and profit shifting (BEPS) and the Two-Pillar Solution, have been studied. The article highlights the disproportion of the international taxation system with the modern challenges of the digital economy. The rapid development of digital technologies gives rise to new forms of business that are difficult to adapt to the existing tax framework. Problems related to determining the location of profits in the digital environment and calculating fair taxation for multinational corporations are becoming obstacles to achieving a balance in the international tax system. The fiscal consequences and impact on international trade and the distribution of tax revenues are analyzed. The article highlights the key trends and challenges that determine the effectiveness and sustainability of the modern international taxation system in the conditions of globalization and the digital economy.

Tax avoidance is an effort taken to reduce tax liabilities and maximize after-tax income that is carried out legally and safely for taxpayers because it does not conflict with tax provisions. The purpose of this study is to analyze the effect of transfer pricing, political connections, on tax avoidance with profitability as a moderating variable in multinational companies in the manufacturing sector listed on the Indonesia Stock Exchange in 2018-2022. The data obtained in this study come from the annual reports of multinational companies in the manufacturing sector listed on the Indonesia Stock Exchange in 2018- 2022. The data analysis technique used in this study was purposive sampling and obtained 66 companies with a research period of 5 years, namely 2018-2022 so that 330 samples were obtained. The analysis method used in this research is multiple linear regression analysis and MRA. The results of this study indicate that the transfer pricing variable has a negative effect on tax avoidance but the transfer pricing variable has a positive effect on tax avoidance with moderating profitability, while political connections have no effect on tax avoidance even with moderating profitability. [ABSTRACT FROM AUTHOR]

The article analyses the latest international tax law developments in dispute resolution settlement protocols and the need for effective multilateral solutions to prevent international double taxation. While several treaties currently minimise the risks of international double taxation, more must be achieved to provide judicial remedies in cases where two states want to tax the same income simultaneously. The OECD has developed a dispute resolution system based on arbitration clauses to be introduced in conventions signed by the state and a brand-new MLI (multilateral instrument) that should be applicable on a broader scale. These remedies have proven unsatisfactory as the taxpayer is not entitled to play any role in these (arbitration) procedures and cannot stand personally in front of any panel. The authors argue that such a scenario is inconsistent with the rule of law and the due process clauses and should be amended. Creating a supranational court with the entitlement to adjudicate the power to tax would be the optimal solution, but this would collide with the position of several states and their distrust of the international judiciary in tax matters. [ABSTRACT FROM AUTHOR]

I estimate the effect of financial constraints on the response of firms that import inputs to a large exchange rate depreciation. Using data from a census on Indonesian firms, I find that while domestic importers face lower value added due to a rise in their costs of production, foreign‐owned importers fare better: they are more likely to sustain higher value added, hire more labor and use more materials than domestic owned firms. These effects are driven by firms in industries with high demand for external finance, emphasizing the importance of access to finance in mitigating the impact of trade and credit shocks. This suggests another channel through which FDI can add value to a firm in a developing country, particularly with the increasing importance of trade in intermediate goods. [ABSTRACT FROM AUTHOR]

This article develops a model showing how information reporters influence information load among decision makers and generate supplier-induced information demand (SID). The intra-corporate information-providing process is an expert market with information asymmetry. I show that information overload occurs as an SID and is the result of informational overconsumption deliberately caused by the supplying reporter. My analysis highlights that the information overload depends on the specificity of information. It also shows that the decision maker may face a hold-up situation in light of switching costs. The more specific the information needed, the higher the threat of information overload. The strategic content of information tempts reporting managers to overload the decision maker for the purpose of increasing their reporting transfer price and to discourage the decision maker from getting the information from another reporting manager. Although the decision maker knows a part of the information demand, information overload involves the cost of using unnecessary inputs, information overload occurs as an SID of information, even if other competing reporting managers exist. My analysis demonstrates that information overload can occur due to uncertainty and opportunism of both the decision maker and reporting managers. [ABSTRACT FROM AUTHOR]

This article is devoted to the study of certain aspects of control by the tax service over the implementation of controlled transactions by taxpayers. The author summarises the main criteria for transactions that fall under controlled transactions. The author emphasises that controlled transactions are under close scrutiny of the tax authorities. These are transactions involving non-residents and affecting the financial result of taxpayers and are carried out: with related non-residents; with non-residents registered in low-tax jurisdictions; with non-residents whose legal form is included in the relevant list; through non-resident commission agents; between a non-resident and its permanent establishment in Ukraine. Since cross-border pricing is one of the ways to minimise taxes, this increases the interest of the controlling authorities. Attention is drawn to both the type of controlled transaction and the income received by the taxpayer based on the results of the activity, which should be considered in the complex. It is emphasised that the main element of the controlled transaction audit is the correct pricing. In this case, the arm's length principle is used for the audit. The Tax Code of Ukraine clearly defines the conditions under which transactions are recognised as not complying with this principle. The author emphasises that in case of violation of this principle, the financial result is adjusted, which entails additional taxation. In addition, attention is focused on the existence of a business purpose (reasonable economic reason) for the controlled transaction, which can only be present if the taxpayer intends to obtain an economic effect as a result of economic activity. The economic effect mainly implies an increase in the taxpayer's assets and/or their value, as well as the creation of conditions for such an increase (preservation) in the future. Taxpayers should focus on the correct pricing not only as a basis for avoiding a tax offence, but also for proper tax planning. [ABSTRACT FROM AUTHOR]

This paper investigates standard cost-based transfer prices in a two-period setting. We analyze whether and how firms should use cost information observed after the first period to revise the transfer price for the second period. Updating the transfer price improves trading decisions if realized cost helps predict future costs, but it causes underinvestment in cost reduction. We find that firms benefit from revising the transfer price based on realized cost instead of keeping it fixed for both periods. Moreover, optimally balancing trade and investment efficiency requires that the firm commits ex ante to a transfer price that does not fully use the information contained in past cost observations to update expected costs in future periods. [ABSTRACT FROM AUTHOR]

Copyright of FinanzRundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Die Unternehmensbesteuerung (Ubg) is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Türkiye Adalet Akademisi Dergisi is the property of Justice Academy of Turkey and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Economic Series of the Bulletin of the L.N. Gumilyov ENU is the property of L.N. Gumilyov Eurasian National University and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

This paper analyzes the transfer pricing decision of the multinational firm. There are differences in profit tax rates between home‐country and host‐country. The multinational firm determines the transfer price to its overseas affiliate and delegates the responsibility of deciding on the final sales to its affiliate manager. We find that: (1) The multinational firm will set a higher transfer price if its affiliate hires a manager. If the host‐country firm also hires a manager, the managerial delegation may lead to an asymmetry "prisoner's dilemma". (2) When home‐country's tax rate is higher than that in the host‐country, multinational firm tends to set a lower transfer price relative to the marginal production cost. (3) When host‐country's tax rate is higher than that in the home‐country, an increase in the host‐country corporate tax rate decreases multinational firm's profit and the consumer surplus, while its impact on the host‐country firm's profit is non‐monotone; an increase in the home‐country tax rate decreases host‐country firm's profit, increases consumer surplus, but has a non‐monotone impact on multinational firm's profit. [ABSTRACT FROM AUTHOR]

Tax payment has been a burden to business organizations, but a source of revenue to government. This study therefore, delved into the influence of government-imposed taxes on the profitability of firms, focusing on Nigerian Oil and Gas Companies. The research revealed that the coefficient of petroleum profit tax (PPT) exhibited a positive (11.28640) and statistically significant impact (P=0.0129<0.05). Similarly, the beta value of customs and excise duty (CED) displayed a positive (96.41566) and statistically significant impact (P=0.0013<0.05). On the other hand, the beta value of value-added tax (VAT) showed a negative effect (-706.1630) that was statistically significant (P=0.3117>0.05). In conclusion, this study demonstrated varying effects of government-imposed taxes on firms' profitability, particularly within Nigeria's oil and gas sector. While petroleum profit tax and customs and excise duty exerted positive and significant effects, value-added tax had a negative impact. Consequently, the study recommends a reduction in the value-added tax rate by the Nigerian government to facilitate the enhanced profitability of select oil and gas companies. Additionally, government should intensify its efforts in improving public infrastructural facilities like good access road, adequate electricity supply and security to assist private companies improve their profitability while reducing their expenses which will serve as an incentive and encouragement to enable them pay their taxes promptly and regularly. [ABSTRACT FROM AUTHOR]

The aim of this paper is to examine the relationship between three determinants – environmental patents, environmental taxation and trade globalization – and the environmental-economic efficiency of 29 OECD countries between 2005 and 2020. Using the Global Malmquist-Luenberger index, this research computes the environmental productivity growth and its main drivers – the catch-up and the frontier shift terms. Besides, dynamic panel linear models are applied to investigate how the three institutional variables affect the dynamics of the computed efficiency indices. Results are as follows: firstly, eco-innovation is the most relevant factor in boosting the environmental productivity growth, pushing forward the technological frontier, and spurring the catch-up term. Secondly, environmental taxation is an ineffective policy instrument in promoting the sustainable growth and technological frontier advancements, having positive impacts only on the catch-up term. Thirdly, trade globalization reveals to hinder the sustainable growth and its two main drivers. [ABSTRACT FROM AUTHOR]

This paper investigates the effects of institutional quality on tax revenue collection in sub‐Saharan African countries. We include the six institutional quality indicators (i.e., voice and accountability, political stability, regulatory quality, rule of law, control of corruption, and government effectiveness) as explanatory factors for tax revenues and its components in a sample of 42 countries over the period 1996–2019. A system GMM approach was used for the estimations. Consistent with previous results, we find that institutional quality has positive and significant effects on tax revenue collection in sub‐Saharan Africa. Specifically, aggregate total tax revenues, direct taxes, income taxes, and goods and services taxes are positively affected by the six institutional quality indicators. Indirect taxes are positively associated with four indicators, with the exception of government effectiveness and political stability, while tax on international trade are affected by institutional quality factors, with the exception of control of corruption and voice and accountability. These findings indicate that sub‐Saharan African countries should improve institutional quality to boost tax revenue collection. [ABSTRACT FROM AUTHOR]

The execution of transfer pricing (TP) audit policies, aimed at deterring tax evasion activities and ensuring adherence to the arm's length principle (ALP) among affiliated parties, is scrutinized in this investigation. This study adopts a qualitative research approach encompassing postpositivism and constructivism, employing data analysis methodologies like triangulation techniques and utilizing NVivo tools such as Coding. The research seeks to elucidate and scrutinize the enforcement of transfer pricing audit policies, pinpoint factors affecting their execution, and devise strategies for managing transfer pricing audits. Findings reveal that the enforcement of TP audit policies can be examined from the contextual policy aspect, encompassing influential interests, decision-making locus, and resource utilization, alongside considerations of policy content, including actor strategies and regulatory characteristics. External factors such as perceptions of the Indonesian tax system and internal factors such as human resource preparedness impact policy execution. Practical implications include the necessity to update operational guidelines, stay abreast of business model advancements, and enhance Customer Relationship Management (CRM) implementation to bolster TP audit efficacy. [ABSTRACT FROM AUTHOR]

Copyright of Journal of Governance & Administrative Reform is the property of Universitas Airlangga and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

This study employs a novel approach based on real options theory to explore how host‐country terrorism influences the location decisions of companies seeking to invest overseas. Using data for publicly listed firms in China that engaged in outward foreign direct investment (OFDI) between 2008 and 2020, this paper reveals that the severity of host‐country terrorism negatively affects the flow of OFDI from Chinese firms to that specific country. Notably, this adverse impact of host‐country terrorism on OFDI is less pronounced for state‐owned enterprises (SOEs) compared to non‐SOEs. Furthermore, the extent of immigrant presence in the host country acts as a mitigating factor against the negative influence of host‐country terrorism on firms' OFDI decisions. A significant contribution of this article is its pioneering examination of the intricate connection between extreme risks such as host‐country terrorism and the firm‐level OFDI location choices. The insights derived from this study can play a crucial role in assisting companies in bolstering their strategies for risk mitigation and security when venturing into foreign markets. Beyond its practical implications, the findings also hold theoretical value, offering a deeper understanding of how a country can maintain a resilient and diversified international economic order, fostering stable trade relationships, and facilitating high‐level engagement with the global economy. [ABSTRACT FROM AUTHOR]

The taxation of multinational income is the subject of important policy debates. For example, the recent Pillar One proposal by the Organisation for Economic Development and Cooperation (OECD) would shift taxing rights from countries in which value is created to countries where it is realized. This study develops and analyzes a model in which a multinational firm creates a valuable intangible asset, referred to as a brand. The brand is developed in one country and generates future positive residual profits in three countries. At the industry level, these residual profits are competed away by many firms that try to create the brand, only one of which succeeds. It compares various methods of allocating multinational profits for tax purposes. Separate accounting using an arm's length royalty that taxes income based on where value is created satisfies the criterion of distributional neutrality. Other methods that allocate some or all income based on where value is realized violates distributional neutrality. [ABSTRACT FROM AUTHOR]

Copyright of Umsatzsteuer-Rundschau is the property of De Gruyter and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Copyright of Crónica Tributaria is the property of Instituto de Estudios Fiscales, Ministerio de Hacienda y Funcion Publica and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Research aims: This paper investigates two control mechanisms that firms can use to avoid negotiation conflicts in negotiated transfer pricing decisions. Design/Methodology/Approach: This experimental research used a 2x2 factorial design between subjects. This study involved 77 undergraduate economics and business students as participants. Research findings: This result revealed that divisions evaluated with systems that value high ethical leadership and competitive performance evaluation schemes would set transfer prices close to equal profit transfer prices. These results suggest that companies with individual performance evaluations in a decentralized corporate structure can use informal controls such as ethical leadership to manage negotiation conflicts. Theoretical contribution/ Originality: This study provides further knowledge to the ethical leadership literature by examining the influence of ethical leadership and performance evaluation schemes on transfer pricing. Previous research on leadership and transfer pricing prediction is limited and primarily focuses on tone leadership. This research, therefore, develops previous research by focusing on another leadership style, namely ethical leadership, with an experimental design. Practitioner/Policy implication: This research provides an easy and low-cost alternative control mechanism to reduce conflicts that can occur in the transfer price negotiation process. Research limitation/Implication: This research is limited to ethical leadership styles and limited transfer pricing mechanisms. Future research, thus, can use other leadership styles and other transfer pricing mechanisms, such as two-step pricing. Different mechanisms used can produce different decisions as well.

In an economy strongly marked by globalisation, transfer pricing is at the top of the agenda of taxpayers, tax authorities and regulatory bodies, with its influence manifested primarily in the fiscal area, respectively in the correct determination and proper allocation of the corporate tax base between different jurisdictions or between companies operating within the same jurisdiction. However, transfer pricing transcends the fiscal problematic and significantly influences other aspects of a company's life, one of which is the image reflected in the annual financial statements, including cash flows or financial performance indicators, and through their analysis, the investment decisions of potential users of accounting information. Transfer pricing is, therefore, also a reference point in the audit work carried out at the level of companies part of national or multinational groups and involved in significant intra-group transactions, as compliance or non-compliance with the arm’s length principle directly influences the way in which different elements of income, expenses, results, assets, equity or liabilities are reflected or not in accordance with the true and fair view principle and thus, ultimately, the audit opinion. National and international auditing standards provide recommendations and guidance on how to deal with transfer pricing issues as part of audit engagements, reflecting a continuing concern by professional bodies to develop best practices in this area. By studying the legislation in force and the available literature as well as by analysing (over a 5 year timeframe, i.e. 2018 - 2022) the information included in the annul financial statements of three companies listed on the Bucharest Stock Exchange, included in the "Constituents index - BET" category, which are part of a group and are involved in transactions with related parties, the objective of this article was to identify the main elements to be considered and analysed in the audit work with regard to transfer pricing. Following the research carried out, it can be concluded that, in accordance with the recommendations and requirements of national and international auditing standards, in the context of audit engagements carried out for companies involved in transactions with related parties, transfer pricing is one of the elements that should be subject to recurrent analysis as its impact on the result of the financial year but also on other elements included in the financial statements (e.g. payables, receivables, etc.) can be significant, directly influencing the true and fair view that they should reflect.

The article presents innovative approaches to improving the risk management process in the context of developing a strategy for foreign economic activity of enterprise. To identify risks and choose the optimal strategy for foreign economic activity of enterprises (FEA), economic and mathematical modelling was used using the risk matrix and the criteria of Bayes, Laplace, Wald, Savage, Hurwitz, Hodge-Lehman. To approbate the results of the study, enterprises of the pharmaceutical industry were selected. According to the theory of games, in order to improve the risk management process, elements of the payment matrix have been applied, which characterize the profit of pharmaceutical enterprises in foreign economic activity. The use of the Hurwitz criterion, which is a criterion of pessimism-optimism, made it possible to choose the optimal strategy for the selected enterprises. The developed matrix of risks of foreign economic activity (strategic, operational, financial and external) for the selection of the optimal strategy of foreign economic activity through the use of economic and mathematical modelling should be used to determine the risks of the greatest impact at different stages of foreign economic activity using the theory of games. The presented matrix of risks of foreign economic activity is built for domestic enterprises of the pharmaceutical industry and is aimed at improving the process of risk management of foreign economic activity, which will enable enterprises of the pharmaceutical industry to predict risks at the early stages of activity and take into account in the general concept of the strategy of foreign economic activity of enterprises. The pharmaceutical industry of Ukraine was chosen for research because it is the most popular in modern conditions, and, according to the results of the analytical review, very high-risk. That is why the use of economic and mathematical modelling for risk calculation allows to optimize the economic behaviour of domestic pharmaceutical enterprises, while providing a reliable basis for making sound strategic decisions in the process of risk management in the context of developing a strategy for foreign economic activity. The risk management process, consisting of 7 stages and 18 steps, has been improved, and innovative tools have been proposed that facilitate the implementation of risk management in the enterprise in the process of developing a foreign trade strategy. The use of economic and mathematical modelling in risk forecasting and the formation of a foreign economic activity strategy will help enterprise managers to significantly increase management efficiency, reduce risks at the stage of planning foreign economic activity. The article improves the risk management process, which consists of 7 stages and 18 steps, and offers innovative tools that facilitate the implementation of risk management in the enterprise in the process of developing a foreign trade strategy. The use of economic and mathematical modelling in risk forecasting and the formation of a foreign economic activity strategy will help enterprise managers to significantly increase management efficiency, reduce risks at the stage of planning foreign economic activity.

We use firm-level data from ASEAN5 to examine the significance of tax-motivated profit shifting by multinational enterprises and to analyze how anti-avoidance measures mitigate the profit shifting. We show that (1) tax-motivated profit shifting is statistically and economically significant, especially for manufacturing firms, (2) auditing and transfer-pricing scrutiny is more effective in reducing profit shifting than documentation requirement alone and (3) tax-motivated profit shifting is prominent for large firms, while anti-tax avoidance measures result in the absence of profit shifting detected from small manufacturing firms. The findings have important implications for developing countries with weak governance but dependent on MNEs.