IDEAS home Printed from https://ideas.repec.org/a/cbu/jrnlec/y2021v6p119-125.html
   My bibliography  Save this article

Practical Approach Regarding The Benchmark Study In The Context Of A Transfer Pricing Analysis

Author

Listed:
  • IOANA IGNAT

    (FACULTY OF ACCOUNTING AND MANAGEMENT INFORMATION SYSTEMS, BUCHAREST UNIVERSITY OF ECONOMIC STUDIES, BUCHAREST, ROMANIA)

Abstract

Transfer pricing subject approached from the perspective of the transfer pricing analysis is relatively a new concept studied within the literature. The process of such an analysis involves the going through several stages, including the performance of a benchmark study (i.e. a study which provides information in relation to the prices/ profitability indicators obtained by independent entities performing similar transactions to that under analysis). The benchmark study is very important in the context of a transfer pricing analysis as based on its results there could be assessed if a related-party transaction complies or not with the arm`s length principle (i.e. if the prices charged within the related-party transaction are at market level). In this context, the objective of the paper is to illustrate based on a case study how should be performed a benchmark study for a related-party transaction which involves the provisions of IT services. In this respect there was used the online version of the Orbis database and the search criteria applied were correlated with the applicable provisions of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (version published in 2017). The main conclusion of the paper is that transfer prices are not an exact science and the benchmark study presented within this paper should not be understood as a universal recipe, but rather as an example based on which the readers could familiarize with the mechanism involved by a benchmark study.

Suggested Citation

  • Ioana Ignat, 2021. "Practical Approach Regarding The Benchmark Study In The Context Of A Transfer Pricing Analysis," Annals - Economy Series, Constantin Brancusi University, Faculty of Economics, vol. 6, pages 119-125, December.
    • Handle: RePEc:cbu:jrnlec:y:2021:v:6:p:119-125
    as

    Download full text from publisher

    File URL: https://www.utgjiu.ro/revista/ec/pdf/2021-06/14_Ignat.pdf
    Download Restriction: no
    ---><---

    References listed on IDEAS

    as
    1. Peralta, Susana & Wauthy, Xavier & van Ypersele, Tanguy, 2006. "Should countries control international profit shifting?," Journal of International Economics, Elsevier, vol. 68(1), pages 24-37, January.
    2. Plesner Rossing, Christian & Cools, Martine & Rohde, Carsten, 2017. "International transfer pricing in multinational enterprises," Journal of Accounting Education, Elsevier, vol. 39(C), pages 55-67.
    3. Pascalis Raimondos-M¯ller, 2002. "Transfer pricing rules and competing governments," Oxford Economic Papers, Oxford University Press, vol. 54(2), pages 230-246, April.
    Full references (including those not matched with items on IDEAS)

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Peralta, Susana & Wauthy, Xavier & van Ypersele, Tanguy, 2006. "Should countries control international profit shifting?," Journal of International Economics, Elsevier, vol. 68(1), pages 24-37, January.
    2. Jean Hindriks & Susana Peralta & Shlomo Weber, 2014. "Local Taxation of Global Corporation: A Simple Solution," Annals of Economics and Statistics, GENES, issue 113-114, pages 37-65.
    3. Jie Ma & Pascalis Raimondos, 2015. "Competition for FDI and Profit Shifting," CESifo Working Paper Series 5153, CESifo.
    4. Kristian Behrens & Susana Peralt & Pierre M. Picard, 2014. "Transfer Pricing Rules, OECD Guidelines, and Market Distortions," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 16(4), pages 650-680, August.
    5. Amerighi, Oscar & Peralta, Susana, 2010. "The proximity-concentration trade-off with profit shifting," Journal of Urban Economics, Elsevier, vol. 68(1), pages 90-101, July.
    6. Jay Pil Choi & Jota Ishikawa & Hirofumi Okoshi, 2024. "Tax havens and cross-border licensing with transfer pricing regulation," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 31(2), pages 333-366, April.
    7. Choi, Jay Pil & Furusawa, Taiji & Ishikawa, Jota, 2020. "Transfer pricing regulation and tax competition," Journal of International Economics, Elsevier, vol. 127(C).
    8. Hong, Qing & Smart, Michael, 2010. "In praise of tax havens: International tax planning and foreign direct investment," European Economic Review, Elsevier, vol. 54(1), pages 82-95, January.
    9. Krautheim, Sebastian & Schmidt-Eisenlohr, Tim, 2011. "Heterogeneous firms, 'profit shifting' FDI and international tax competition," Journal of Public Economics, Elsevier, vol. 95(1-2), pages 122-133, February.
    10. Hsun Chu, 2014. "Tax Enforcement Policy and the Provision of Public Goods with the Presence of Tax Havens," Scottish Journal of Political Economy, Scottish Economic Society, vol. 61(3), pages 304-321, July.
    11. Haufler, Andreas & Runkel, Marco, 2012. "Firms' financial choices and thin capitalization rules under corporate tax competition," European Economic Review, Elsevier, vol. 56(6), pages 1087-1103.
    12. Dominika Langenmayr & Franz Reiter, 2022. "Trading offshore: evidence on banks’ tax avoidance," Scandinavian Journal of Economics, Wiley Blackwell, vol. 124(3), pages 797-837, July.
    13. Sebastian Krautheim & Tim Schmidt-Eisenlohr, 2016. "Wages and International Tax Competition," Review of International Economics, Wiley Blackwell, vol. 24(5), pages 893-923, November.
    14. Tatiana Dănescu & Maria Alexandra Botoş, 2018. "Analysis of Companies' Behaviour in Smoothing Conflicts of Interest," Annals of the University of Petrosani, Economics, University of Petrosani, Romania, vol. 18(1), pages 45-56.
    15. Wolfgang Eggert & Jun-Ichi Itaya, 2014. "Tax Rate Harmonization, Renegotiation, and Asymmetric Tax Competition for Profits with Repeated Interaction," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 16(5), pages 796-823, October.
    16. Schreiber, Ulrich & Overesch, Michael & Büttner, Thiess & Wamser, Georg, 2006. "The Impact of Thin-Capitalization Rules on Multinationals? Financing and Investment Decisions," ZEW Discussion Papers 06-068, ZEW - Leibniz Centre for European Economic Research.
    17. Becker, Johannes & Fuest, Clemens, 2012. "Transfer pricing policy and the intensity of tax rate competition," Economics Letters, Elsevier, vol. 117(1), pages 146-148.
    18. Hayato Kato & Hirofumi Okoshi, 2022. "Economic Integration And Agglomeration Of Multinational Production With Transfer Pricing," International Economic Review, Department of Economics, University of Pennsylvania and Osaka University Institute of Social and Economic Research Association, vol. 63(3), pages 1325-1355, August.
    19. Hiroshi Mukunoki & Hirofumi Okoshi, 2025. "Wake Not a Sleeping Lion: Free Trade Agreements and Decision Rights in Multinationals," Review of International Economics, Wiley Blackwell, vol. 33(3), pages 505-518, August.
    20. Bucovetsky, Sam & Haufler, Andreas, 2008. "Tax competition when firms choose their organizational form: Should tax loopholes for multinationals be closed," Journal of International Economics, Elsevier, vol. 74(1), pages 188-201, January.

    More about this item

    Keywords

    ;
    ;
    ;
    ;

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:cbu:jrnlec:y:2021:v:6:p:119-125. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Ecobici Nicolae The email address of this maintainer does not seem to be valid anymore. Please ask Ecobici Nicolae to update the entry or send us the correct address (email available below). General contact details of provider: https://edirc.repec.org/data/fetgjro.html .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.