Oguttu, Annet Wanyana
Challenges of applying the comparability analysis in curtailing transfer pricing evaluating the suitability of some alternative approaches in Africa / Annet Wanyana Oguttu .-- , 2020
Resumen.
This article asserts that transfer pricing is perhaps the greatest profit shifting problem facing the international tax system. Thus, countries have historically been keen on preventing transfer pricing and on finding effective and efficient methods for allocating revenue that are administratively cost effective for both taxpayers and tax administrators. However, the problem as articulated in this article is that the comparability analysis that underpins the application of the arm's length principle (ALP) which is applied internationally to curb transfer pricing, continues to be a vexing problem for developing countries due to various conceptual, policy, legislative, administrative and capacity challenges in finding comparable data
PRECIOS DE TRANSFERENCIA
OPERACIONES VINCULADAS
ÁFRICA
Intertax 0165-2826 v. 48, Issue 1, January 2020, p. 74-102
Challenges of applying the comparability analysis in curtailing transfer pricing evaluating the suitability of some alternative approaches in Africa / Annet Wanyana Oguttu .-- , 2020
Resumen.
This article asserts that transfer pricing is perhaps the greatest profit shifting problem facing the international tax system. Thus, countries have historically been keen on preventing transfer pricing and on finding effective and efficient methods for allocating revenue that are administratively cost effective for both taxpayers and tax administrators. However, the problem as articulated in this article is that the comparability analysis that underpins the application of the arm's length principle (ALP) which is applied internationally to curb transfer pricing, continues to be a vexing problem for developing countries due to various conceptual, policy, legislative, administrative and capacity challenges in finding comparable data
PRECIOS DE TRANSFERENCIA
OPERACIONES VINCULADAS
ÁFRICA
Intertax 0165-2826 v. 48, Issue 1, January 2020, p. 74-102