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"Transfer pricing"
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Some solutions to combat tax base erosion in Vietnam
Tax base erosion poses a significant challenge to tax collection and financial stability in Vietnam. This study explores potential solutions to address tax base erosion in Vietnam today. The study employs analytical and comparative methodologies to evaluate the current state of tax base erosion in Vietnam and propose viable solutions. Firstly, it is imperative to enhance the effectiveness of tax management by adopting advanced technology and comprehensive workforce training. Furthermore, implementing stringent regulations on transfer pricing and deploying measures to deter tax avoidance can mitigate profit shifting and tax evasion perpetrated by multinational corporations. International collaboration also holds a pivotal role, involving the ratification of tax treaties and active engagement in global initiatives such as the OECD’s BEPS framework. Lastly, fostering a competitive business environment and promoting economic diversification can reduce dependence on industries susceptible to tax erosion. The Vietnamese government can effectively counter tax base erosion by integrating these measures, safeguarding fiscal stability, and fostering socio-economic progress.
Journal Article
On the dynamics between local and international tax planning in multinational corporations
The international dimension of multinational corporations creates opportunities for pursuing both global as well as local (i.e., unilateral subsidiary country) tax planning strategies. To date, however, researchers have limited insights into both the dynamics and relative importance of one versus another strategy for multinationals. We propose and test a group-level ETR-based measure of profit shifting and validate it by showing it correctly identifies profit shifting reductions when shifting costs increase. We confirm that multinationals can keep group ETRs stable after the introduction of tighter tax compliance and documentation rules and suggest they can do so by relying relatively more on local tax planning. In line with the substitution argument, we document that especially groups identified as ex-ante income shifters as well as those with greater target ETR pressure are responsible for the results.
Journal Article
AI-Enabled Management of Transfer Pricing Documentation: A Sustainable Governance Framework Integrating Compliance, Digitalization, and CSRD Requirements
Tax administrations are undergoing rapid digitalisation, while sustainability requirements are increasingly embedded in corporate governance frameworks. These parallel transformations are raising new expectations for transfer pricing (TP) documentation, which must be accurate, transparent, and audit-ready. This paper investigates the extent to which artificial intelligence (AI)—specifically natural language processing (NLP), robotic process automation (RPA), and machine-learning techniques—can support a sustainability-oriented governance framework for TP documentation in multinational enterprises. Using a longitudinal case study of the OMEGA Group, operating across 21 jurisdictions, we analyse an AI-enabled documentation architecture that streamlines data extraction, enhances comparability analysis, and strengthens audit preparedness, in line with the OECD Transfer Pricing Guidelines and relevant European Union regulatory requirements. The empirical evidence indicates substantial improvements in documentation efficiency (−68.3%), a significant reduction in processing errors (−81.5%), and higher audit acceptance rates (+27%). Beyond compliance, AI-driven digital workflows contribute to sustainability objectives by reducing resource consumption, improving data traceability, and facilitating alignment with CSRD-related reporting requirements. Overall, the findings demonstrate that AI-enabled TP documentation can evolve into a strategic pillar of sustainable tax governance, provided that its outputs remain explainable, auditable, and grounded in professional judgment. The study proposes an integrated governance framework that connects digital transformation, regulatory compliance, and sustainability within contemporary TP management practices.
Journal Article
Draining development? : controlling flows of illicit funds from developing countries
The book provides the first collection of analytic contributions, as opposed to advocacy essays and black box estimates, on illicit financial flows (IFFs). Some of the chapter presents new empirical findings; others, new conceptual insights. All of them enrich the understanding of the dynamics of the illicit flows phenomenon. The book does not offer a new estimate of the global total of these flows because the phenomenon is too poorly understood. The chapters are based on papers first presented at a September 2009 conference at the World Bank. Each paper had one or two assigned discussants, and the revisions reflect the often searching critiques of the discussants, as well as additional comments from the editor and from two external peer reviewers. The chapters have been written to be accessible to non-experts. Following this introduction, the book has five parts: the political economy of illicit flows; illegal markets; to what extent do corporations facilitate illicit flows? Policy interventions; and conclusions and the path forward.
eBook
Influence of the profitability of tax rates and exchange rates one determining transfer pricing decisions: An Empirical Evidence from Indonesia
Transfer pricing is a significant issue in the sphere of business and taxation. In various countries, the development of international and multinational corporations can boost the practice of transfer pricing. However, some of them are not based on the arm's length price. This research is aimed to analyze the effextivity profitability tax rate and exchange rate toward the firm decision of transfer pricing. The dependent variable in this research is transfer pricing substituted by the value of related party transaction (RPT) of sales. The independent variables in this research are effective tax rate, profitability, and exchange rate. This study employs secondary data obtained from accessible annual report of 29 multinational corporations listed on Indonesian stock exchange in 2016-2019. The data analysis utilizes regression analysis method or a sample selection according to specific criteria. The results of the analysis in this research show that effective tax rate and exchange rate have a positive and significant influence toward the firm decision of transfer pricing. While profitability does not affect the firm decision of transfer pricing.
Journal Article
Modeling a Financial Controlling System for Managing Transfer Pricing Operations
The management of transfer pricing operations is considered from the perspective of modeling financial and accounting processes for various organizations, using agricultural enterprises as an example. It is demonstrated that the execution of transfer pricing operations between related parties—which may function as responsibility centers within an organizational holding structure—serves as a managerial lever influencing the financial income and expenses of individual business units. It is revealed that the developed model of managerial accounting for transfer pricing operations, grounded in tax compliance and the balancing of stakeholder interests, is based on two key aspects: first, to ensure the balanced development of the company’s business units, a list of key performance indicators (KPIs) is developed and integrated into a balanced scorecard (BSC), promoting the sustainable and stable operation and growth of the company; second, with access to this list of KPIs, the manager of each business unit can exert indirect influence over a segment of the final product’s value chain by selecting transfer prices that adhere to the arm’s length principle. The practical application of the proposed model is illustrated using previously formed economic operations from the research base.
Journal Article
Anti profit-shifting rules and foreign direct investment
This paper explores the effects of unilateral tax provisions aimed at restricting multinationals’ tax planning on foreign direct investment (FDI). Using a unique dataset which allows us to observe the worldwide activities of a large panel of multinational firms, we test how limitations of interest tax deductibility, so-called thin-capitalization rules, and regulations of transfer pricing by the host country affect investment and employment of foreign subsidiaries. The results indicate that introducing a typical thin-capitalization rule or making it more tight exerts significant adverse effects on FDI and employment in high-tax countries. Moreover, in countries that impose thin-capitalization rules, the tax-rate sensitivity of FDI is increased. Regulations of transfer pricing, however, are not found to exert significant effects on FDI or employment.
Journal Article
Location-Specific Advantages
This book discusses location-specific advantages, a novel concept originating from the transfer pricing practice in China and India.
eBook