Examining the Alternative Approaches to Comparability Analysis in Transfer Pricing | Chapter 8 | Business, Management and Economics: Research Progress Vol. 10

Comparability analysis provides evidence of compliance with transfer pricing regulations to show that intercompany transactions are conducted at arm’s length prices as is required in most jurisdictions. The concept of comparability in transfer pricing is a multidimensional concept, with product and functional comparability as two of the commonly discussed dimensions. This paper introduces a third dimension to comparability in transfer pricing, that of market comparability. In addition, the concept of comparability as a whole including the interaction between product, functional, and market comparability was examined.

 

Author (s) Details

Arthur S. Leahy
7315 Inzer St., Springfield, VA 22151, USA.

 

Please see the book here:- https://doi.org/10.9734/bpi/bmerp/v10/3655

Examining Approaches to Transfer Pricing Under I.R.C. Section 482 | Chapter 9 | Recent Trends in Arts and Social Studies Vol. 7

 I review the systems of transfer pricing adjustment secondhand by the IRS for transfers of real and intangible property 'tween related parties. These arrangements include the corresponding uncontrolled price method, the resale price system, the cost-plus method, the comparable profits methods, the profit split method, and the corresponding uncontrolled transaction design. An example, using the corresponding profits methodology, is again shown.

Author(s) Details:

Arthur S. Leahy

Please see the link here: https://stm.bookpi.org/RTASS-V7/article/view/11777

Thought Experiment Transfer Pricing Alternatives: Supporting John M. Clark’s Workable Competition Pricing

 The object of this study is to analyze numerical results for a thought experiment comparing transfer pricing alternatives of a hypothetical corporation having a manufacturing division making a single product and a marketing division that sells that product. Each division seeks to maximize its own profits. The marketing division faces hypothetical fluctuating demand fluctuations, prosperity versus depression, for a final product that is semi-perishable costly to store such as cement. The manufacturing division has two alternate technologies, high fixed cost versus low fixed costs. The transfer pricing alternatives: A) short-run marginal cost pricing high price volatility over the business cycle versus B) John M. Clark’s workable competition pricing low price volatility over the business cycle. The manufacturing division plants have linear total cost functions with absolute capacity limits. In opposition to perfect competition theory, this study argues in support of John M. Clark (1884-1963) workable competition theory. The thought experiment shows a gain in consumer surplus and to corporate profits over the cycle with transfer pricing John M. Clark’s workable competition theory. This article offers reasons for this gain. This thought experiment should inspire other researchers to do similar hypothetical thought experi-ments.

Author(s) Details:

Gerald Aranoff,
Ariel University, Ariel 40700, Israel.

Please see the link here: https://stm.bookpi.org/CABEF-V9/article/view/9295

Determining the Taxable Income Differential between Foreign- and Domestic Companies in Saudi Arabia | Chapter 1 | Modern Perspectives in Economics, Business and Management Vol. 8

 The purpose of this research is to examine if, as a result of transfer pricing policies, there is a difference in tax paid based on revenue differentials between Saudi Arabian domestic oil companies and foreign-owned oil companies operating in the nation. The process of assessing the income of all parties involved in international economic transactions is known as transfer pricing (TP). The sample will include 13 domestic and 8 international enterprises. Borvornboonrutai (2001) used a number of linear regression equations to better understand the variables related to transfer pricing and the level of taxes paid by domestically-owned vs overseas corporations operating in Thailand. The research' findings clearly show that the amount of taxes paid by the oil businesses investigated in this study varies based on their origin. Saudi Arabian-owned enterprises pay lesser taxes in relation to their revenues than companies owned by foreigners. The real difference in tax rates was roughly 4.5 percent, and statistical tests confirmed that it was statistically significant.

Author (S) Details

Ali Faya Alhassan
College of Business, King Khalid University, Saudi Arabia.

Mohammed Saleh Bajaher
College of Business, King Khalid University, Saudi Arabia and College of Administrative Science, Aden University, Yemen.

View Book :- https://stm.bookpi.org/MPEBM-V8/article/view/3645

Study on Transfer Pricing: A Case of Saudi Arabia | Chapter 5 | Modern Perspectives in Economics, Business and Management Vol. 2

 This study examines transfer pricing behaviour in the context of the Saudi oil and gas sector, as well as that of a number of other countries (e.g., Australia, Canada, Czech Republic, France, Korea, Japan, Kuwait, Norway, Poland, Sweden, UK, and US). The technique of Bartelsman and Beetsma [1] is proposed as the foundation for evaluating the hypothesis. The findings of this study show that the Bartelsman and Beetsma [1] model fails to detect transfer pricing for the aim of shifting profit when applied to the Saudi Arabian oil and gas sector. When the Bartelsman and Beetsma [1] model is applied to additional countries, such as Japan, Korea, Norway, Poland, and the United Kingdom, it produces results that show the incidence of transfer pricing behaviour for the purpose of shifting profits.

Author (s) Details

Dr. Ali Faya Alhassan
College of Business, King Khalid University, Saudi Arabia.

View Book :- https://stm.bookpi.org/MPEBM-V2/article/view/2323