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
Date Written: January 8, 2018
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: Suggested Citation