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Transfer Pricing (Transfer mispricing (Aritificial price (Sale, Purchase),…
Transfer Pricing
Transfer mispricing
Aritificial price
Sale
Purchase
Multinational
Org B
Org A
Arm's length principle
Market Price
Sales
Purchase
Multinational
Org B
Org A
Alternative approach
Unitary (apportionment) taxation
Tax portions of multinationals the same
Compatible with country by country reporting (The Justice Network)
Obstacles
Path dependency
Arms-length practice already established
Vested interest
Maintain status quo
Technical issues
Formula is complex to create
Lost tax
Estimates differ
Potential
Christian Aid report 2009
$1.1 Tn
Traditional international approach
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Tax paid
Tax avoided
Realistic price
Artificial price
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