Challenges of applying the comparability analysis in curtailing transfer pricing evaluating the suitability of some alternative approaches in Africa Annet Wanyana Oguttu
By: Oguttu, Annet Wanyana
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Material type: 
ArticlePublisher: 2020Subject(s): PRECIOS DE TRANSFERENCIA | OPERACIONES VINCULADAS | ÁFRICA
In:
Intertax v. 48, Issue 1, January 2020, p. 74-102Summary: 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
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| Artículos | IEF | IEF | OP 2141/2020/1-6 (Browse shelf) | Available | OP 2141/2020/1-6 |
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| OP 2141/2020/1-3 The hybrid financial instruments | OP 2141/2020/1-4 The troubled story of the Hungarian advertisement tax | OP 2141/2020/1-5 Advance pricing arrangements | OP 2141/2020/1-6 Challenges of applying the comparability analysis in curtailing transfer pricing | OP 2141/2020/1-7 UN MTC Article 8 | OP 2141/2020/3 Intertax | OP 2141/2020/3-1 Lost in construction |
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
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