Transfer pricing and sustainability electrónico need for a “FARME” approach Smarak Swain and Sunny Bilaney
By: Swain, Smarak
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Contributor(s): Bilaney, Sunny Kishore.
Material type: 
ArticleSubject(s): PRECIOS DE TRANSFERENCIA | RIESGO | ANALISIS FACTORIAL | PRIMER PILAR (OCDE) | MERCADOS FINANCIEROS | SOSTENIBILIDAD FISCAL | PAISES EN DESARROLLO
In:
International Transfer Pricing Journal v. 29, n. 5, p. 328-330Summary: Function, asset and risk (FAR) analysis is a mainstay of transfer pricing analysis. Through Pillar One, the OECD acknowledges the need for a new taxing right for market [M] jurisdictions (i.e. it aims its trajectory towards FAR[M] analysis). However, in the authors’ view, there is a need for a tectonic reform in transfer pricing to account for the negative externalities (for instance, environmental and climate risk) in transfer pricing analysis in order to support developing economies in achieving sustainability goals. For this purpose, the authors have suggested a thought-provoking concept of FARME (i.e. function, assets, risk, market and externalities) analysis, including how such externalities should be factored into the transfer price.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2022/5-11 (Browse shelf) | Available | ITPJ/2022/5-11 |
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Disponible únicamente en formato electrónico
Resumen
Function, asset and risk (FAR) analysis is a mainstay of transfer pricing analysis. Through Pillar One, the OECD acknowledges the need for a new taxing right for market [M] jurisdictions (i.e. it aims its trajectory towards FAR[M] analysis). However, in the authors’ view, there is a need for a tectonic reform in transfer pricing to account for the negative externalities (for instance, environmental and climate risk) in transfer pricing analysis in order to support developing economies in achieving sustainability goals. For this purpose, the authors have suggested a thought-provoking concept of FARME (i.e. function, assets, risk, market and externalities) analysis, including how such externalities should be factored into the transfer price.
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