(2 rânduri libere, 11p)
Studies and Scientific Researches. Economics Edition, No 36, 2022 http://sceco.ub.ro
6
THE TRANSFER PRICING FILE AND TAX CONTROVERSIES
- AN EMPIRICAL STUDY
Anatol Melega
Ștefan cel Mare University of Suceava, Romania
melega.anatol@gmail.com
Mărioara Molociniuc (Hritcan)
Ștefan cel Mare University of Suceava, Romania
hritcan.maria@usm.ro
Anamaria Geanina Macovei
Stefan cel Mare University of Suceava, Romania
anamaria.macovei@usm.ro
Abstract
Transfer pricing is a real challenge for both tax regulators and multinationals who use this
procedure, in most cases to erode the tax base. The purpose of this paper is to analyse the tax
practices and regulations of countries applying OECD transfer pricing regulations. To this
end, the profiles of 69 countries on the application of transfer pricing regulations and methods
of assessing the transfer pricing file have been analysed. The research results indicate that
countries with developed economies and high tax burdens have more rigid transfer pricing tax
regulations, the aim of which is to prevent tax evasion through transfer pricing. At the same
time, emerging economies with a more lenient tax system do not pay particular attention to
transfer pricing, but provide clear regulations on the methods of assessing the transfer pricing
case. At the other end of the spectrum there are weakly developed countries, which apply
OECD transfer pricing regulations but are flawed in their practical application. The results of
the research are of real use both to national and international regulators and to multinationals
applying transfer pricing in intra-group transactions.
Keywords
transfer pricing; tax controversies; fiscal burden; tax evasion.
JEL Classification
M40
Introduction
The accelerated development of the world's economies has intensified the process of
internationalisation of companies, with an increase in the number of multinationals,
which play an important role in the growth and sustainable development of countries.
Multinationals and their subsidiaries are an important link in the world economy,
accounting for about a third of global gross domestic product and world output.
Multinationals are also important sources of foreign direct investment for emerging
and developing economies. To make themselves more attractive to multinationals,
governments around the world have adopted various strategies such as: upgrading
infrastructure; easing tax regulations; adopting international accounting standards;
adopting regulations to ensure their investment security; reducing investment
restrictions, etc. Multinationals are more likely to open subsidiaries in countries that
have a more lenient tax regime and at the same time are rich in natural resources and
cheap labour. These characteristics are attributed to emerging economies, which are
Melega, Molociniuc (Hritcan), Macovei
7
the main recipient of FDI inflows due to abundant natural resources and a low tax
burden.
Multinationals have been involved in various financial scandals over the years, which
have strained the international economic system. Most of the financial scandals in
economic history are related to false reporting of earnings (Waste Management
Scandal 1998), falsification of financial results (Worldcom Scandal 2002, Healthsouth
Scandal 2003), manipulation of stock market prices (American Insurance Group
Scandal 2005), etc. The rise of multinationals has highlighted a weak link in the
international tax field, namely the taxation of their profits. To protect investors and
prevent tax avoidance, national and international regulators have therefore joined
forces to draw up guidelines on the taxation of multinationals and transfer pricing,
which is one of the most widely discussed international tax issues. Multinationals
often resort to transfer pricing, which represents the value of intra-group transactions,
as the simplest and most common method of tax minimisation by multinationals to
erode the tax base. Basically, through transfer pricing, multinationals transfer the tax
base artificially by redistributing the indicators that make up the tax base among the
multinational's subsidiaries. Due to tax synergies, multinationals using transfer
pricing manage to use a preferential tax regime without violating national and
international law. The application of transfer pricing by multinationals in the absence
of clear tax mechanisms and policies regulating its use reduces the state's ability to
collect budget revenues and at the same time gives multinationals a free hand for
economic crime. In this regard, the OECD has developed "Transfer Pricing
Guidelines for Multinational Enterprises and Tax Administrations", which has a dual
purpose, for governments "to ensure that multinationals' profits are not artificially
transferred from their jurisdiction and that the tax base reported by multinationals in
their country reflects the economic activity carried out there" and for multinationals to
ensure "that the risk of economic double taxation is limited" (OECD, 2022). This
guide is used in 69 jurisdictions around the world, which is also the focus of our
research. In addition, the OECD Transfer Pricing Guidelines "provide guidance on the
application of the arm's length principle, which is the international consensus on the
valuation of cross-border transactions between associated enterprises" (OECD, 2022).
Therefore, the aim of our research is to analyse the profile of countries applying
OECD transfer pricing tax practices and regulations and to highlight the main issues
in multinational taxation. Thus, to achieve the proposed aim we have outlined the
following objectives: O1: analysis of the determinants of transfer pricing; O2:
analysis and evaluation of transfer pricing tax regulations and practices in the 69
jurisdictions applying the OECD guidelines. The results of the research are of real use
to both national and international regulators and multinationals applying transfer
pricing in intra-group transactions. The limitations of the research are that due to the
rather large sample and its non-homogeneity (countries are from different economies:
predominantly developed, emerging, developing and underdeveloped economies) the
results of the study are too general.
Literature review
The issue of taxation of multinationals has attracted the attention not only of national
and international tax regulators, but also of researchers, who are examining the effects
of transfer pricing on the level of development of countries and its impact on the
global foreign direct investment circuit (Melega et al., 2023). At the same time, some
researchers have focused their attention on the usefulness of transfer pricing methods
recommended by tax regulators. For example Kardos et al. (2016) analysed transfer
pricing methods and concluded that although tax authorities provide multinationals
THE TRANSFER PRICING FILE AND TAX CONTROVERSIES - AN EMPIRICAL STUDY
8
with a multitude of methods, their use in practice is cumbersome due to the lack of
transaction history and level of legal regulation. According to the OECD guide,
multinationals can apply one of five methods for transfer pricing, namely: "the
comparable uncontrolled price method (CUP), the resale price method (RPM), the
cost plus method (CPM), the net transaction margin method (TNMM) and the
transaction profit split method (TPSM)" (see Table 1). In applying transfer pricing
methods, multinationals should take into account the "arm's length principle, which is
a commonly used expression to refer to transactions in which two or more unrelated
parties agree to do business, acting independently and in their own interest" (OECD,
2022).
Table 1. OECD transfer pricing valuation methods
Method Explanations and definitions
The CUP Method
"The CUP method compares the price charged for property
or services transferred in a controlled transaction to the
price charged for property or services transferred in a
comparable uncontrolled transaction in comparable
circumstances. If there is any difference between the two
prices, this may indicate that the conditions of the
commercial and financial relations of the associated
enterprises are not arm's length, and that the price in the
uncontrolled transaction may need to be substituted for the
price in the controlled transaction" (OECD, 2022).
The Resale Price
Method
"The resale price method begins with the price at which a
product that has been purchased from an associated
enterprise is resold to an independent enterprise. This price
(the "resale price") is then reduced by an appropriate gross
margin (the "resale price margin"), determined by
reference to gross margins in comparable uncontrolled
transactions, representing the amount out of which the
reseller would seek to cover its selling and other operating
expenses and, in light of the functions performed (taking
into account assets used and risks assumed), make an
appropriate profit" (OECD, 2022).
The Cost Plus
Method
"The cost plus method begins with the costs incurred by
the supplier of property or services in a controlled
transaction for property transferred or services provided to
an associated enterprise. An appropriate mark-up,
determined by reference to the mark-up earned by
suppliers in comparable uncontrolled transactions, is then
added to these costs, to make an appropriate profit in light
of the functions performed and the market conditions"
(OECD, 2022).
The Transactional
Net Margin Method
"The transactional net margin method ("TNMM")
examines a net profit indicator, i.e. a ratio of net profit
relative to an appropriate base (e.g. costs, sales, assets),
that a taxpayer realises from a controlled transaction (or
from transactions that are appropriate to aggregate) with
the net profit earned in comparable uncontrolled
transactions" (OECD, 2022).
Melega, Molociniuc (Hritcan), Macovei
9
The Transactional
Profit Split Method
"The transactional profit split method first identifies the
combined profits to be split for the associated enterprises
from the controlled transactions in which the associated
enterprises are engaged. In some cases, the combined
profits will be the total profits from the controlled
transactions in question" (OECD, 2022).
Source: OECD (2022)
Transfer pricing methods have been developed with the aim of providing
multinationals with legal tools for intra-group transfers and at the same time to
exclude and prevent economic crime. The multitude of transfer pricing methods is to
the advantage of multinationals as it gives them the possibility to optimise intra-group
transactions and thus avoid sanctions from tax regulators. According to Radolovic
(2012), "the decision making process on transfer pricing optimization has two
dimensions that need to be taken into account: the optimization dimension in terms of
available capacity, tax laws of countries, available market and other indicators of the
individual company and the dimension of international transfer pricing regulation in
line with the OECD Guidelines." Therefore, in order for multinationals to benefit
from optimal transfer pricing and competition, transfer pricing assessment methods
must examine all the sides mentioned by Radovic (2012). Of the many methods
available to multinationals, they must use the one that corresponds to their business
and provides an objective assessment of the transaction price and tax base, but in
practice, they aim to use methods that lead to profit maximisation and tax
minimisation, i.e. to shape a good image and position in the market. Based on the
assumption that "the application of different transfer pricing methods affects the
amount of the tax base", Šupuković (2021) analysed the possibilities of tax avoidance
in transactions between the parent company and subsidiaries within the group,
concluding that "the application of different transfer pricing methods affects the
amount of the tax base of each business entity, thus confirming the basic assumption
of the paper and that the study of transfer pricing is not exact, and in this context, the
choice of the final transfer pricing solution should be based on several possible
outcomes, i.e. comparable market prices." In practice, the lack of an international
framework for taxing multinationals and of clear transfer pricing regulations provides
niches for tax base erosion and tax avoidance through transfers to subsidiaries
operating in tax havens. The solution to combat economic crime through transfer
pricing is to establish a single global tax rate and reduce the tax burden, which is the
main incentive for transactions to tax havens. As Lucian (2010) argues, "tax evasion
is the result of inadequacies in the law, of the methods of enforcement, of the lack of
provision for the main causes of evasion or of a tax policy considered excessive by
taxpayers", and in order to prevent and combat it, national and international bodies
must commit to drawing up common regulations that do not constrain or provide
taxpayers with loopholes for such practices. In this regard, the OECD, through Pillar
II of international tax reform, has come up with a proposal to tax multinationals at a
minimum of 15%, a rule that applies to multinationals and groups of companies with
combined financial revenues of more than EUR 750 million per year (European
Commission, 2022). The effectiveness of this reform will be felt when all the world's
governments have implemented this resolution, which is currently applied by 137
countries. An important effect of the 15% minimum tax on multinationals will be the
one that it will reduce the number of transfer pricing transactions. At the same time,
the new tax rule will contribute to increasing tax revenues in most of the economies
that will apply this rate and will contribute to achieving Sustainable Development
Goal (SDG) target 17.1: "mobilise and strengthen domestic resources, including
THE TRANSFER PRICING FILE AND TAX CONTROVERSIES - AN EMPIRICAL STUDY
10
through international support to developing countries, to improve domestic capacity
to collect taxes and other revenues" (SDGs, 2022). According to Lassourd (2022),
"the impact of global minimum tax rules will depend on their interaction with
domestic tax policies and how different countries change their tax regimes as a
result." In this vein, the following research questions emerge:
Q1: Do tax regulations and policies for assessing and establishing transfer pricrs
correspond to the current economic developments and the needs of multinationals and
governments in collecting tax revenues objectively?
Q2: Do existing tax regulations and policies for assessing and establishing the
transfer prices eliminate and prevent any form of tax avoidance?
Research methodology
The present research is a quantitative questionnaire-based research, i.e. the OECD
"Transfer Pricing Country Profile" questionnaire, which provides data on transfer
pricing regulations, methods, documentation and agreements, making possible the a
comparative analysis of transfer pricing in 69 jurisdictions (see Table 2). The OECD
questionnaire was applied individually to each country and outlines the level of
transfer pricing regulation in each economy and their compliance with the OECD
guidelines. The questionnaire consists of both open and restricted questions, which
were analysed using quantitative methods.
Table 2. Countries included in the analysis
Korea, Rep. China Jamaica Chile Ireland Switzerland Ukraine
Angola Dominican Republic Georgia Uruguay Germany
New
Zealand Senegal
Nigeria Tunisia Italy France Austria Russia Argentina
Papua New
Guinea Brazil Cameroon Belgium Denmark Maldives Albania
Honduras Columbia Costa Rica USA Iceland Mexico Panama
Netherlands India Israel Portugal Sweden Armenia Romania
Kenya Africa Southern Spain Malta Luxembourg Indonesia Bulgaria
Turkey Greece Lithuania
Mary
Great
Britain
Finland Peru Malaysia
Croatia Hungary Poland Slovakia Latvia Slovenia Czech Republic
Estonia Japan Singapore Australia Canada Norway
Source: developed by the author
In order to analyse the level and quality of tax regulations and practices in the 69
selected jurisdictions and to answer the research questions, using multiple linear
regression, we defined a quality index of transfer pricing tax regulations and practices
(qqtpr), which was also considered the dependent variable of the model. Seven
independent variables were established as independent variables based on the OECD
questionnaire, reflecting the methods, regulations and tax and legal practices of
transfer pricing establishing and assesment (see Table 3).
The linear regression model was defined by the function:
Melega, Molociniuc (Hritcan), Macovei
11
, i=1,..,n.
where, n is the sample size.
Based on the selected variables (see Table 3), the linear regression equation was
defined as:
Table 3. Description and definition of independent variables in research
Variables Description
Iqtpr Quality index of transfer pricing regulations and tax practices
Alprp The arm's length principle and defining related parties
Lcitpr Level of comparability of information for transfer pricing purposes
Rtpriav Regulations for determining the transfer price of intangible assets,
intangible values
Gitav Guidance specific to intragroup transactions with low added value
Ftr Financial Transactions Regulations
Tprd Transfer pricing documentation regulations
Adj Adjustments at the end of the year and secondary adjustments
Source: developed by the author
In this research we used multiple linear regression because it is an essential tool for
diagnosing and identifying problem cases, and the aim of our research is to identify
the strengths and weaknesses of tax valuation and transfer pricing regulations and
practices in the 69 jurisdictions, which apply OECD transfer pricing regulations. At
the same time, as Aiken et al. (2003) state, multiple regression (MR) analysis
provides flexibility for modelling data and examining relationships between predictor
(independent) variables and the dependent variable.
Result and discussions
The regulation of transfer pricing has become an important topic for national and
international regulators, this subject initiating various discussion platforms for the
development of an appropriate legal framework for the objective assessment of
transfer prices in order to avoid any form of tax avoidance. The non-taxation of
multinationals' income is the main concern of political actors and professionals
involved in tackling transfer pricing issues. At the same time, existing tax regulations
on transfer pricing taxation are strongly criticised (Rogers & Oats, 2022) and are the
subject of debates among regulators and practitioners as to their effectiveness and
their adaptability to recent geopolitical changes. The lack of clear transfer pricing
regulations, puts transfer pricing professionals in a difficult position, because
according to Rogers and Oats (2022) they "require substantial practical knowledge
and experience accumulated over time, including not only the theoretical application
of the ALP (The arm's length principle), but also the agreements reached in practice."
The quality of tax regulations and practices for assessing and setting transfer prices
has negative effects not only on the efficiency of the state in collecting its revenues,
but also on the flow of foreign direct investments. According to De Mooji and Liu
(2018) "unilateral adoption of transfer pricing regulations can have a negative impact
on actual investment by multinationals.” Given the importance of transfer pricing to
the international business environment, transfer pricing regulations are reviewed and
supplemented annually. For example, the latest revisions have come with
explanations of the range of competition used to determine the market price of a good
THE TRANSFER PRICING FILE AND TAX CONTROVERSIES - AN EMPIRICAL STUDY
12
or service, so regulators are trying to eliminate any dispute over the correct
application of transfer pricing rules and principles. The introduction and extension of
transfer pricing regulation helps to reduce the risk of tax avoidance by limiting the
transfer of profits between businesses. Reidel and Zin (2014) argue that this behaviour
of the authorities is not surprising, as the introduction of "anti-avoidance measures to
prevent taxpayers from adjusting transfer prices for tax purposes" ensures the
efficiency of the state in revenue collection, thus preventing the development of large-
scale ecomic crime.
Table 4. Model Summaryb
Model R R
Square
Adjusted R
Square
Std. Error of
the Estimate
Durbin-
Watson
1 .753a .568 .518 .288017 1.382
a. Predictors: (Constant), Adj, Lcitpr, Rtpriav, Tprd, Gitav, Ftr, Alprp
b. Dependent Variable: Iqtpr
Source: developed by the author
Therefore, according to the data in the above table, we can see that the predictor
variables quality index of transfer pricing regulations and tax practices; the arm's
length principle and defining related parties; level of comparability of information for
transfer pricing purposes; regulations for determining the transfer price of intangible
assets, intangible values; guidance specific to intragroup transactions with low added
value; financial transactions regulations; transfer pricing documentation regulations;
Adjustments at the end of the year and secondary adjustments influence the quality
index of transfer pricing regulations and tax practices, the dependent variable, in a
proportion of 56.8% (see Table 4). In practice, the current level of transfer pricing
regulation in the analysed 69 jurisdictions is covered to the extent of 56.8%, which
shows that current regulations do not fully cover this area. Lack of regulation also
leads to increased economic crime through transfer pricing.
Table 5. ANOVAa
Model Sum of
Squares
df Mean
Square
F Mr
1 Regression 6.645 7 .949 11.444 .000b
Residual 5.060 61 .083
Total 11.706 68
a. Dependent Variable: Iqtpr
b. Predictors: (Constant), Adj, Lcitpr, Rtpriav, Tprd, Gitav, Ftr, Alprp
Source: developed by the author
The model designed to assess the quality of tax valuation and transfer pricing
regulations and practices for the 69 jurisdictions was validated as the Sig. significance
threshold value is 0.000 , which is below the 0.05 threshold (see Table 5).
Table 6. Coefficientsa
Model Unstandardized
Coefficients
Standardiz
ed
Coefficient
t Mr
Melega, Molociniuc (Hritcan), Macovei
13
s
B Std.
Error
Beta
1 (Constant) .059 .191 .312 .756
Alprp .536 .236 .578 2.270 .027
Lcitpr -.134 .070 -.366 -
1.918
.060
Rtpriav .132 .129 .126 1.028 .308
Gitav .004 .141 .003 .026 .980
Ftr .089 .137 .084 .648 .519
Tprd .267 .153 .239 1.744 .086
Adj .135 .102 .147 1.332 .188
a. Dependent Variable: Iqtpr
Source: developed by the author
According to the regression coefficients, the regression equation is outlined as:
The quality of tax regulations and practices for assessing and setting transfer prices,
according to the correlation table, is influenced by the predictor variables in the
following order: The arm's length principle and defining related parties (Alprp), Level
of comparability of information for transfer pricing purposes (Lcitpr), Transfer
pricing documentation regulations (Tprd), Adjustments at the end of the year and
secondary adjustments (Adj), Regulations for determining the transfer price of
intangible assets, intangible values (Rtpriav), Financial Transactions Regulations
(Ftr), Guidance specific to intragroup transactions with low added value (Gitav). The
application of the arm's length principle and the comparability of information are
essential elements in the correct and objective determination of transfer prices.
According to the model data, it can be seen that the arm's length principle is applied
and the comparability of information, i.e. the history of transactions, is taken into
account in setting and assessing transfer prices in the 69 jurisdictions, allowing for
objective and market-based transfer pricing. At the same time, it is noted that there
are overlaps in the 69 jurisdictions in terms of regulations and practices for setting
and valuing transfer prices of intangible assets, financial transactions and low value
added intra-group transactions. At the same time, from the analysed sample, which
includes countries from different types of economies and levels of development, it is
evident that countries with developed economies and high tax burdens have more
rigid transfer pricing tax regulations aimed at preventing tax evasion through transfer
pricing, while emerging economies do not pay particular attention to transfer pricing,
but provide clear regulations on the methods of assessing the transfer pricing record,
while underdeveloped countries, which apply OECD transfer pricing regulations, are
lagging behind in their practical application. Thus, according to our results, we
succeed in answering our research questions Q1 and Q2, concluding that tax
regulations and policies for transfer pricing assessment and determination do not
correspond to economic actuality and the needs of multinationals and governments in
the objective collection of tax revenues, and fail to prevent and eliminate tax evasion.
THE TRANSFER PRICING FILE AND TAX CONTROVERSIES - AN EMPIRICAL STUDY
14
Figure 1 Histogram and Plot Regression
Source: developed by the author
According to the figure above, it can be seen that the histogram distribution of the
variable quality index of transfer pricing regulations and tax practices is a multimodal
distribution, because several variables were analyzed in the model, which have a
normal distribution, and the distribution of the trend line on the Q-Q Plot of the
variable is non-homogeneous.
Conclusions
The level and quality of transfer pricing regulation is a key factor in preventing and
combating tax evasion. Therefore, national and international regulators should join
forces to identify and establish clear rules and standards that leave no room for
interpretation and are easy to apply in practice. Setting a minimum tax rate of 15% for
multinationals can be a start in discouraging multinationals from applying transfer
pricing to erode the tax base. The effects will only be felt once all governments
around the world will commit to adopt OECD transfer pricing rules into national
regulations, thus creating a common front in the fight against economic crime.
Our research has shown that the arm's length principle is applied in 69 jurisdictions
for setting and assessing transfer prices and that comparability of information like
transaction history, is taken into account, allowing for objective and market-based
transfer pricing. At the same time, the results of the research show that there are
overlaps across the 69 jurisdictions in the regulation and practice of transfer pricing of
intangible assets, financial transactions and low value-added intra-group transactions.
At the same time, from the analysed sample, which includes countries from different
types of economies and levels of development, it is evident that countries with
developed economies and high tax burdens have more rigid transfer pricing tax
regulations aimed at preventing tax evasion through transfer pricing, while emerging
economies do not pay particular attention to transfer pricing, but provide clear
regulations on the methods of assessing the transfer pricing record. Regarding the
underdeveloped countries, which apply OECD transfer pricing regulations, they are
lagging behind in their practical application.
In the same vein, the results of the research indicate that current tax regulations and
policies for assessing and establishing transfer prices do not correspond to the current
Melega, Molociniuc (Hritcan), Macovei
15
economic situation and the needs of multinationals and governments in the objective
collection of tax revenues, and fail more or less to prevent and eliminate tax evasion.
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