Challenges and Issues in Transfer Pricing: In Specific Context of Advertisement, Marketing and Promotion

Towards Excellence: A Journal of Higher Education, UGC Human Resource Development Centre, Gujarat University, Ahmedabad, Jan., 2018. Vol.10. Special Issue for International Youth Symposium, ISSN: 0974-035X, pp. 108 – 122.

15 Pages Posted: 19 Apr 2018

See all articles by Pawan K. Chugan

Pawan K. Chugan

Nirma University - Institute of Management; AIIM - Ahmedabad; SPM - PDPU

Jitendra Nenavani

Nirma University - Institute of Management, Students

Date Written: January 8, 2018

Abstract

Transfer pricing remains an inevitable tool for MNCs to carry out intra-company transactions. From the literature, misuse of transfer pricing has been observed with respect to advertisement, marketing and promotion (AMP). This research paper attempts to demonstrate the instances wherein abuse of transfer pricing was witnessed in transactions dealing with intangibles. Being difficult to measure and because of certain legality issues, transactions involve in AMP have been exploited for tax-evasion purposes. Apart from the concepts, this paper also stresses upon the mechanism through which the process of transfer pricing in MNCs can be smoothened and litigations can be avoided.

Note: Note: by B. K. School of Business Management, Gujarat University, Ahmedabad and is published in a Special Issue of the Towards Excellence: A Journal of Higher Education (Ed), Nilam Panchal, and is uploaded with the permission of the B. K. School of Management, Gujarat University.

Keywords: International Transfer Pricing, Advertisement Marketing & Promotion, Advance Pricing Agreements (APAs), Safe Harbour Rules (SHRs)

JEL Classification: E62, F21, F23, H2, H32, H87

Suggested Citation

Chugan, Pawan Kumar and Nenavani, Jitendra, Challenges and Issues in Transfer Pricing: In Specific Context of Advertisement, Marketing and Promotion (January 8, 2018). Towards Excellence: A Journal of Higher Education, UGC Human Resource Development Centre, Gujarat University, Ahmedabad, Jan., 2018. Vol.10. Special Issue for International Youth Symposium, ISSN: 0974-035X, pp. 108 – 122. , Available at SSRN: https://ssrn.com/abstract=3153906

Pawan Kumar Chugan (Contact Author)

Nirma University - Institute of Management ( email )

Sarkhej Gandhinagar Highway
Ahmedabad, GUJARAT 382481
India

HOME PAGE: http://pawanchugan.wordpress.com

AIIM - Ahmedabad ( email )

Adani Shantigram, Vaishno Devi Circle
S.G. Highway
Ahmedabad, Gujarat 382421
India

HOME PAGE: http://pawanchugan.wordpress.com/

SPM - PDPU ( email )

Raisan
Gandhinagar, Gujarat 382007
India

HOME PAGE: http://pawanchugan.wordpress.com/

Jitendra Nenavani

Nirma University - Institute of Management, Students ( email )

Sarkhej-Gandhinagar Highway
Chandlodia, Via : Gota
Ahmedabad
India

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