CHAPTER 3

External Influences on Transfer Pricing

Introduction

Not that long ago, transfer pricing was a subject for tax administrators and one or two other specialists. But, more recently, businesspeople, economists, and politicians, as well as a number of nongovernmental organizations, have been waking up to the importance of who pays tax, on what, and perhaps importantly where, on international business transactions between different arms of the same business enterprise. Globalization is one reason for this interest, and the rise of MNEs is another. Once you take on board the fact that more than 60% of world trade takes place within these MNEs, the importance of transfer pricing, both internally and externally, becomes clear.

Most of the ...

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