Abstract

The global business landscape is dominated by multinational enterprises (MNEs) with intricate networks of subsidiaries operating across borders. This interconnectedness presents a unique challenge as how to determine the appropriate price for goods and services exchanged internally between these affiliated entities. This is where the concept of transfer pricing comes into play. Transfer pricing refers to the process of establishing prices for transactions between related parties under common control. Unlike typical market transactions, these internal transfers lack the arm's length principle, where unrelated buyers and sellers negotiate a fair price based on market forces.The revenue of both parties to a cross-border transaction is ascertained via transfer pricing. Therefore, the tax bases of the nations involved in cross-border transactions tend to be shaped by the transfer price. In business economics, a transfer price is defined as the price that one division of an organization charges another division of the same organization for a good or service that the former division provides. Recognizing the potential for profit shifting, governments around the world have implemented transfer pricing regulations based on the OECD's arm's length principle. Tax authorities closely scrutinize transfer pricing practices to ensure compliance and collect their fair share of tax revenue. This has led to increased international cooperation and efforts to establish standardized transfer pricing guidelines.

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