International Transfer Pricing in Multinational Enterprises

            In this research, there is a detail discussion about the international transfer pricing in multinational enterprises. There are many of the factors involve in the multinational enterprise's transaction such as tax regulations, OECD guidelines, trade institutions and policy makers. For the qualitative research, the secondary data collection method will be used, and for the quantitative research, primary data collection methods will be used.  The variables include government regulations, OCD transaction guidelines, the geographical location of the transaction, market levels, type of services retail versus wholesale, and date and time of the transaction. The profit margins are calculated on the basis of the product price. Compare table uncontrolled price method is also used in the market for intragroup transactions in external, internal market prices, and multinational Enterprises group. In this research study, a random sampling method will be used for data collection. In this research all of the ethical principles and rules are followed. It will be ensured in this research study that all of the data collected is authentic and information is accurate. In the secondary research, the data is collected from the authentic websites, journals, books and online resources.

Introduction of International Transfer Pricing in Multinational Enterprises

            In the multinational enterprises, the transfer of the prices is an important aspect in the accounting and finance management. Within the same country with the transfer of the prices occur for the distribution of the same country it is done for a non-tax purpose and in the same time when it comes to transferring the prices in multinational enterprises the tax is also involved in the transaction. So it can be said that there are many of the factors involved in the multinational enterprise's transaction such as tax regulations, OECD guidelines, trade institutions, and policymakers. In this research paper, there would be a discussion about the different factors involved in the international transfer pricing in multinational enterprises. In a variety of Management Accounting, Transfer pricing is considered as a controlling process of issues performance and responsibility centers. In a variable type of transfer prices such as non-tax purpose, the controllers and Management Accounting are traditionally involved (Hiemann & Reichelstein, 2012).

            However, sometimes intra-group cross border transactions are also used in Multinational Enterprises. It is particularly used when tax compliance becomes dominant and attract more attention from the management. Multinational Enterprises often emphasize on the tax compliance and increases the scope of complexity for the Transfer pricing tax regulation (Schön & Konrad, 2012). Generally, the international Transfer pricing is becoming intensive subject that attracts more attention of stakeholders including policymakers, trade Institutions, and tax authorities. The economic cooperation and Development Department of organizations emphasis on Action Plan for profit shifting and base erosion solutions (Baldenius, Bastian, & Reichelstein, 2005). The comprehensive Action Plan prevents tax avoidance in the companies and uses different schemes including International Transfer pricing without the taxing. The pricing transfer method is used to reduce the inefficiency of international Tax rules and different arbitration mechanisms. Some reports suggested that introduction to simplified transfer pricing mechanism related to the Administrative Services is an evaluation technique for the intangible used in the intra-group transaction (Dutta & Reichelstein, 2010).

           In addition to that new comprehensive documentation, packages are provided for the value creation and additional information of value chain in the country by country considerations. In multinational Enterprises, the international Transfer pricing is listed as the top of Strategies for international tax agenda. Multinational Enterprises often select only a single set and then International Transfer pricing continues for managerial purposes and tax reporting purposes (Baldenius, Melumad, & Reichelstein, 2004). In different corporations, the Income-Tax rates are characterized by international locations and the text-based transfer prices. However, understanding of tax based Transfer pricing is essentially required for implementation and to improve the business strategies (Rossing, Cools, & Rohde, 2017).

        In the current Management Accounting strategies, the importance of tax perspective of international Transfer pricing is increased (Rossing, Martine, & Rohde, 2017). The present analysis considers the objective of transfer pricing and responsibility of accounting domain for this process. In the context of Management Accounting and professional careers in the globalized business, the present work analysis Management Accounting studies for the international Transfer pricing regulations and responsibility of the accounting department for the performance measurement. The other issues related to the practices are perceived as critical non-tax issues of the transfer pricing (Cools, Emmanuel, & Jorissen, 2008).

Research Problem of International Transfer Pricing in Multinational Enterprises

        The international transfer pricing in multinational enterprises become more complex because factors like tax regulations and trade institutions are involved in the transaction. For the multinational companies, the transfer of prices can be a complicated issue because of the involvement of arbitration mechanisms and international tax rules. So it can be said that for the multinational organization, the management of accounting and financing because of the international transfer pricing can be a problem.

Research Objectives of International Transfer Pricing in Multinational Enterprises

The main objectives of this research study are as follow:

To study the factors involves international transfer pricing in multinational enterprises.

To recognize the arbitration mechanisms and international tax rules that the multinational enterprises needed to consider while doing international transfer pricing.

To understand the accounting practices change because of the implications of international taxes.

Research Questions of International Transfer Pricing in Multinational Enterprises

The main questions of this research study are as follow:

What are the factors involves in the international transfer pricing in multinational enterprises?

What are the arbitration mechanisms and international tax rules that the multinational enterprises needed to consider while doing international transfer pricing?

What are the accounting practices change because of the implications of international taxes?

Significance of Research of International Transfer Pricing in Multinational Enterprises

            This research will be carrying it by using the secondary as well as the primary resources that will increase the reliability of this study. This research will be a good piece of information for the researchers in the future who wants to take this research further.  This research will also fill the gaps in the previous researches related to the topic of international transfer pricing in multinational enterprises. The present search provides fundamentals of Management Accounting and how are multinational Enterprises considered the transfer pricing in actual. There are two objectives of the present work, the first objective is to develop analytical understanding and thinking skills for the technical competencies and how to apply OECD guidelines in the business (Baldenius, Bastian, & Reichelstein, 2005).

        The present research specially provides insight into the fundamental requirements in which multinational Enterprises comply and it also analyses the transferred pricing policies used by Multinational Enterprises. The guidelines provided by OECD provide numerical information about fictional multinational enterprise Taxpayers. In the present analysis, materials and questions are used to address relevant tax correlation and transitional pricing situations and how professionals will take the decision (Dutta & Reichelstein, 2010). Research with narrow the gap between the compliance pressure that is faced by multinational Enterprises and superficial treatment associated with the tax principles of transfer pricing in the current situation.

        The second purpose of the research is to understand the managerial implications for the transfer pricing. The analysis considered as a domestic Transfer pricing concept introduced to the responsible accounting department (Baldenius, Bastian, & Reichelstein, 2005). Transfer pricing and tax, Optimization is also used to attract media attention. The present analysis provides guidance on the regulatory requirements and different implementations for the responsible accounting department regarding performance development (Rossing, Cools, & Rohde, 2017). The specific learning objectives of the present research are listed below,

To improve the ability for analyzing intra-group transaction subjects and identifying the arm length principle implementation in Multinational Enterprises.

To develop an ability related to transfer pricing method analysis and to understand the market data availability.

To improve the ability of comparative analysis for calculation of arms-length Transfer pricing (Cools, Emmanuel, & Jorissen, 2008).

Improve the ability to understand managerial accounting implementations particularly for the international Transfer pricing.

To develop analytical thinking skills about the decision-making process in multinational companies.

Literature Review of International Transfer Pricing in Multinational Enterprises

          According to the research conducted by Rossing, Cools, & Rohde, (2017) it is reviewed that the present management accounting programs focus on the transfer pricing role as an instrument for computing the responsibility centers their manager’s performance. In recent times, on the other hand, multinational enterprises have sensed accumulative pressure to comply with tax regulation of the transfer pricing (Rossing, Cools, & Rohde, 2017). As an effect, risk management concerns of the tax perform a major role in the decisions related to the today multinational enterprises transfer pricing. This situation search for providing examples of the international transfer pricing core principles and also to permit to deliberate global transfer pricing in the responsibility accounting context (Rossing, Cools, & Rohde, 2017).

        According to the research conducted by Chan & Lo, (2004) it is reviewed that the connotation among the perception management of the significance of ecological variables and their international transfer pricing approach choice in the developing economy context. Assumed the sizable flowing investment to rising nations and the economic exchange amount that happens via overseas investment in countries, it considers this is an important matter. The significant management sees the local partners interests and the good relationship maintenance with host administration to be, the likelihood that FIE will use a transfer pricing technique based on market (Chan & Lo, 2004).

        In a multinational organization, Transfer pricing is playing a central role for managerial accounting as well as for tax reporting purposes. The most common purpose of transfer pricing is ultimately determining the distribution of reported income across different segments of the company (Hiemann & Reichelstein, 2012). The statistical analysis conducted in different multinational organizations very 2003 analyzed maximizing operating performance at 73% in the multinational organization. The optimizing text arguments were at 68%. The literature related to managerial accounting has a long view of Transfer pricing in Multinational Enterprises (Baldenius, Bastian, & Reichelstein, 2005). The whole process considers sales decisions and production coordination of business segments.

        The transfer pricing is intended to improve divisional manager process regarding profitability and cost considerations in intercompany transactions. In the performance analysis, the divisional management is frequently considered for allocation of resource functions and facilities (Baldenius, Melumad, & Reichelstein, 2004). The fascinating process includes the transfer of services and goods across the different divisions of the company. A similar survey conducted in German Enterprises by Ernst & Young (2003) concluded that 48% respondents considered Transfer pricing as text compliance exercise viral 36% of the respondents believed in achieving operational objectives and managerial objectives by the strong influence of transfer functions. While considering the tax-oriented literature on the transfer function some multinational firms have Monolithic view (Rossing, Cools, & Rohde, 2017; Dutta & Reichelstein, 2010).

        The research conducted by Ernst and Young during 2003, it is identified the relationship between a single set of transfer pricing records and multinational companies’ strategies. According to the transfer pricing analysis the internal performance and profit measurement increases by applying a single set Transfer pricing. The consistency in Planning decisions for different segments of business increases and decreases the internal violation of specific transaction differences. The singer set up transfer prices are available for the practices and cooperation development that minimizes over artist liability and it becomes comparable to arm’s length standard principal (Baldenius, Bastian, & Reichelstein, 2005).

        Studies by Wilson and spring Steel suggested that 77% of respondent’s corporate managerial accounting for crucial tax dimensions related to the transfer prices. At the same time, the discussion included the most prevalent Transfer pricing methods that are particularly market-based, cost-based and Transfer pricing of negotiation. The possible decoupling increases with the tax admissible transfer prices. The concessional issue is related to cash flows of text securities and the value of transactions made by Multinational Enterprises (Hiemann & Reichelstein, 2012). A normative statement is based on the goal congruence. The research article focusses on the transfer of tangible property. The study includes consideration for market-based Transfer pricing and cost-based Transfer pricing.

        The particular pricing policy meets with the goal coherence and quality of product traded through International. In the case of cost-based transfer pricing products and would that transfer from one business segment to another business segment with no functional issues of pricing (Rossing, Cools, & Rohde, 2017). In Multinational Enterprises, the management department calculates the internal Transfer pricing and cost of the product after being transferred. Hyde and Choe (2005) and Choe and Hyde (2007) played a significant role in analyzing the prices of multinational Enterprises for internal price and tax reporting purpose is used by companies. The different identifier used in the research mentioned that mostly multinational Enterprises are compatible with the arm’s length standard principle. The fundamental issues multinational enterprises are related to optimal incentive and moral hazards (Cools, Emmanuel, & Jorissen, 2008). These issues were mainly modeled and portrayed in previous researches, for instance, Eccles and White (1988), Kaplan and Atkinson (1998), Tang (1993), and Horngren et al. (2009).

        The model represented by Baldenius et al. (2004) consider the immediate product values and unit price of product compatible with the uncontrolled price analysis and arm length standard principal. In this analysis, the unit cost is calculated that represents selling divisions opportunity cost for the external revenues (Cools, Emmanuel, & Jorissen, 2008). In another research, the researchers Goex and Schiller (2008) and Pfeiffer et al. (2011) identify the specifications of the Framework for fixed cost charges and lump sum charges. Dutta and Reichelstein (2010) examine another model related to the upstream division that makes a sequence of capital investment and capacity analysis (Hiemann & Reichelstein, 2012). In this analysis depreciation charges and optimal transfer, prices are included to reflect the long-term marginal cost for the production of a product. The cost for capacity and services are also included in this model.  Sahay's (2003) represent the desirable model for the transfer pricing in Multinational Enterprises (Baldenius, Melumad, & Reichelstein, 2004).

        This transfer price is a markup of the marginal cost that provides an estimation of profit motives and it is controlled for the production. In order to identify transferable price-weighted average rule and tax admissible transfer prices are considered (Dutta & Reichelstein, 2010). Bastian and Reichelstein, (2005) worked on the analysis of Timken company where the upstream division supplies specialty steel that is developed by using raw material Input and roller bearings. In this survey of Transfer pricing document the company frequently used internal transfer, price is for the discount and external market prices (Rossing, Cools, & Rohde, 2017). Considering the broader perspective on this debate of transfer pricing in Multinational Enterprises, Schoen (2010) conducted a deep analysis of intangible assets and consumable inputs for multiple periods of times and then analyze economic benefits of a multinational company. The research was similar to the discussion made by Johnson (2006) (Baldenius, Bastian, & Reichelstein, 2005).

        Drucker (2010) illustrated the transfer process of Technology in Google and how it is transferred in multi European countries. Transfer process of Technology is associated with a low average tax rate in different European operations. Boos (2003) and Baldenius (2006) worked to illustrate settings of a multinational company in two divisions. The production process contributes to intangible assets substitute (Hiemann & Reichelstein, 2012). The natural extension of this model presented for the tax liability is related to upstream division and receives future benefits and contribution are made for the downstream division. Nöldeke and Schmidt (1998) examine the efficiency of negotiation in the Asset transfer process. The effective negotiation in the business affected the suitability and complimentary of the investment. Therefore it has more tendency to overinvest (Cools, Emmanuel, & Jorissen, 2008).

Research Framework of International Transfer Pricing in Multinational Enterprises

        Research is based upon OECD guideline for the 5 compatibility factors and to identify the market transactions made by Multinational Enterprises. The intra-group transactions are considered for functional analysis, business strategies, and economic circumstances, characteristics of services and properties, and contractual terms. Differences in the characteristics of services and products have an impact on the market and price of the product (Cools, Emmanuel, & Jorissen, 2008). Therefore, the characteristics of product and services are also considered. The products and services that are being transferred by multinational Enterprises Group of Companies should be determined for the excess in different terms and the compatibility within the market transaction. The specific characteristics of the services and products include the product features and quality of the product (Rossing, Martine, & Rohde, 2017).

        The functional analysis in the open market depends upon the price of the product and performance of functions. There is a certain risk associated with the transactions and asset contribute to the independent seller argument. Based on the prices of the product, the higher functions are performed that assume asset value and risk associated with the transfer of the product. The independent sellers often argue for the higher prices and more functionality with the services (Rossing, Martine, & Rohde, 2017). The transfer prices of the product in the multinational Enterprises depend upon the distribution of function and manufacturing process of the product. Dependable variables and tangibles are manufacturing process and brand name (Dutta & Reichelstein, 2010). The other valuable considerations are product inventory and manufacturing equipment of the product. Specific types of risk are associated with the production and input process. The input prices fluctuation is highly important. The intra-group trade required formal contracts relevant to the business systems such as responsibilities and rights of intra-group transaction companies (Dutta & Reichelstein, 2010).

Dependent Variable: International Transfer Pricing

Independent Variable: Tax Regulations

Independent Variable: OECD Guidelines

Hypothesis of International Transfer Pricing in Multinational Enterprises

The main hypothesis of this research study are as follow:

Ha0:

international transfer pricing is likely to increase the complexity of accounting in multinational enterprises.

Ha1:

international transfer pricing is not likely to increase the complexity of accounting in multinational enterprises.

Hb0:

The arbitration mechanisms and international tax rules are needed to consider while doing international transfer pricing multinational enterprises.

Hb1:

The arbitration mechanisms and international tax rules are not needed to consider while doing international transfer pricing multinational enterprises.

Hc0:

Accounting practices in multinational enterprises are changed because of the implications of international taxes.

Hc1:

Accounting practices in multinational enterprises are not changed because of the implications of international taxes.

Methodology of International Transfer Pricing in Multinational Enterprises

Research Design of International Transfer Pricing in Multinational Enterprises

        In this research study, qualitative as well as quantitative research method will be used. For the qualitative research, the secondary data collection method will be used, and for the quantitative research, primary data collection methods will be used. In this study, for the primary research questionnaire method will be used, and for the secondary research, previous literature will be analyzed. In the market economy, the services and price of products have an influence on the pricing transaction process. It means that a significant number of variables have a potential impact on the prices. The variables include government regulations, OCD transaction guidelines, the geographical location of the transaction, market levels, type of services retail versus wholesale, and date and time of the transaction (Rossing, Martine, & Rohde, 2017). In order to, ensure the compare ability, market transaction and multinational Enterprises intra-group should be examined on the basis of economic circumstances.

        In the business strategies, a significant impact of prices on the market economy can be examined. The present analysis includes price distribution in the market transaction under the harvest strategy of products. Final lifecycle and final stages compare for all the transactions and market entry strategies are also important. The comparison of intra-group transaction in multinational Enterprises is based on marketing penetration strategies (Cools, Emmanuel, & Jorissen, 2008). The present report shows that prices are significantly lower for market share. The multinational Enterprises uses five Transfer pricing methods that also use arm's length transfer price standard principal. These principles include Comparable uncontrolled price method (CUP), Resale price method (RP), Cost plus method (CP), Transactional net margin method (TNMM), and Profit split method (PS). Compare apple market prices are applied to intra-group transactions (Hiemann & Reichelstein, 2012).

        The profit margins are calculated on the basis of the product price. Compare table uncontrolled price method is also used in the market for intragroup transactions in external, internal market prices, and multinational Enterprises group. Another method considered by multinational Enterprises is the resale price method. The OECD guidelines suggest that one or more than two gross margin methods, the CB method, and the RP method can be used to identify price charges. One-sided RP method is used to examine reseller price in Multinational Enterprises. The profit split method is also used to identify net profit generated in intra-group transactions (Cools, Emmanuel, & Jorissen, 2008).

Sampling Technique of International Transfer Pricing in Multinational Enterprises

    In this research study, a random sampling method will be used for data collection. The random sampling method is suitable for this research study because it takes very less time, and the data collection is also very easy to analysis.

Sample Size of International Transfer Pricing in Multinational Enterprises

    In this research study, the data will be collected from the tax officials in the government and the managers of the multinational enterprises to know about the factors that affect the transfer of prices. The data will be collected from 250 respondents from which 50 will be the government tax officials, and the rest of 200 will be the managers in the multinational enterprises.

Data Collection Method of International Transfer Pricing in Multinational Enterprises

        In this research, for the primary data, the survey/ questionnaires method will be used, and for the secondary data, previous journals, books, and articles will be analyzed. For a survey, the permission will be granted from the authorities via email to get the response on the questionnaire. The responses from the respondents will get on voluntarily bases. All of the questions in the questionnaire will be made depending on the variables in the study and for each variable there would be more than 2 questions in the questionnaires that would help to find out the relationship between different variables used in this research study.

SPSS Software of International Transfer Pricing in Multinational Enterprises

        The SPSS software will be used for data collection and analysis.  In this research study the use of SPSS software would be appropriate because in this software the whole process of data collection and analysis is easy. All of the statistical test such as regression, ANOVA, Coefficient in the research study would also conduct by using the SPPS software.

Ethical considerations of International Transfer Pricing in Multinational Enterprises

        For any research study, it is very important to follow the ethical rules so that the whole process of the study can be carried out smoothly. In this research all of the ethical principles and rules are followed. In this research study, for the questionnaires the permission is granted from the multinational enterprises officials through emails. The survey will be conducted from the respondents on volunteer basis, so that none of the respondent would have any issue in responding to the survey.

        The respondents can quite the survey any time if they are not comfortable in responding to the questionnaires. In this research study, it will be ensured to all of the respondents that their data will kept confidential and would not be used for any of the commercial purpose. It will be ensured in this research study that all of the data collected is authentic and information is accurate. In this research the protecting confidentiality and anonymity is also essential.

Reliability of research of International Transfer Pricing in Multinational Enterprises

        In this research study all of the data whether it is primary or secondary is collected from the authentic resources that increase the reliability of the study. In the secondary research, the data is collected from the authentic websites, journals, books and online resources. This research furthering the work of the previous researchers to fill the gap in it. All of the data collected from the respondents will be computed on the software to analyses the authenticity of the research. Because all of the data is collected from the authentic resources so that the findings of the research are correct and valid.

Limitations of research of International Transfer Pricing in Multinational Enterprises

There are also some of the limitation of the research study that is also needed to recognize to specify the credibility of this research. The major limitation in this study is the time constricts because the time provide to complete the research was limited that reduce the overall credibility of the research. The second limitation is that the data is collated in the areas and the multinational enterprises in a city that can limit the vast understand of the research topic and because at local level all of the firms are working under same economical and governmental system that can make the result restricted and the data might be different in other cities and countries.

Results Analysis of International Transfer Pricing in Multinational Enterprises

        All of the data collected from the software will be analyzed to interpret the relationship between variables. The software will be used to apply the statistical test such as regression, ANOVA, Coefficient on the data collected. The results of analysis show standard responsibility accounting and there are two main objectives of the study. In the first process, analytical thinking skills are considered for the technical competences and for implementation of OECD guidelines. The specific results are based on the fundamental requirements of MNEs and determines the transfer pricing policies. The OECD guidelines are used for numerical information and for the MNE taxpayer (UH groups). The pricing situation helped in identifying and narrowing the gap between the superficial treatment of tax principle and relevant tax-based transfer pricing compliance pressure MNEs (Rossing, Cools, Rohde, Carsten, 2017). The managerial implication for transfer pricing was used for the tax optimization and attracted alleged tax evasions. After completing the analysis, results were extracted from the voluntary survey filled by the students. The results are considered on the basis of five scale Likert testing in which 1 represented strongly agree, 2 represented agree, 3 represented Neither Agree nor Disagree, 4 represented Disagree and 5 represented Strongly Disagree. The responses were based on the OECD guideline and feedback was used to find the final outcomes. The specific characteristics considered in the present work are product features and quality of services. The case topic visual overview of UH group transaction got potential points as 2 and the 86 % student population correctly addressed the issues. The further detail of analysis is listed below in the table 1 (Rossing, Cools, & Rohde, 2017).

Conclusion on International Transfer Pricing in Multinational Enterprises

            Summing up the discussion about the international transfer pricing in multinational enterprises, it can be said that mostly in multinational Enterprises the common practices are to use single set of transfer pricing rules. The process accounts for transaction between different businesses segments located in different countries around the globe. The transfer pricing rules are similar to accounting rules that uses the tax reporting and investigate internal profit measurement. The optimal arm length transfer principle is used to standardize the transaction. Recently the growing number of companies are considering about distorted internal profit measurement and cost of national. The modelling scenario in this present work was to illustrate the potential use of transfer prices in multinational Enterprises and benefits of the strategies used in multinational companies. It is expected from the research that there will be a positive relationship between all variables of the research. In this section, the final views on the study will be provided once the research is done.

        The guidelines provided by OECD provide numerical information about fictional multinational enterprise Taxpayers. Transfer pricing and tax, Optimization is also used to attract media attention. This situation search for providing examples of the international transfer pricing core principles and also to permit to deliberate global transfer pricing in the responsibility accounting context. The fascinating process includes the transfer of services and goods across the different divisions of the company. The singer set up transfer prices are available for the practices and cooperation development that minimizes over artist liability and it becomes comparable to arm’s length standard principal. The fundamental issues multinational enterprises are related to optimal incentive and moral hazards. In this survey of Transfer pricing document the company frequently used internal transfer, price is for the discount and external market prices. The natural extension of this model presented for the tax liability is related to upstream division and receives future benefits and contribution are made for the downstream division.

References of International Transfer Pricing in Multinational Enterprises

Baldenius, T., Bastian, N., & Reichelstein, S. (2005). Market-Based Transfer Pricing: A Synthesis of Recent Studies. J. Weber and M. Meyer.

Baldenius, T., Melumad, N., & Reichelstein, S. (2004). Integrating Managerial and Tax Objectives in Transfer Pricing. Accounting Review, 79(03), 591-615.

Chan, K. H., & Lo, A. W. (2004). The influence of management perception of environmental variables on the choice of international transfer-pricing methods. The International Journal of Accounting, 93 – 110.

Cools, M., Emmanuel, C., & Jorissen, A. (2008). Management control in the transfer pricing tax compliant multinational enterprise. Accounting, Organizations and Society, 33(06), 603-628.

Dutta, S., & Reichelstein, S. (2010). Decentralized Capacity Management and Internal pricing. Review of Accounting Studies, 15(01), 442-478.

Hiemann, M., & Reichelstein, S. (2012). Transfer Pricing in Multinational Corporations: Transfer Pricing in Multinational Corporations:. Transfer Pricing in Multinational Corporation, 01(01), 01-16.

Rossing, C. P., Cools, M., & Rohde, C. (2017). International transfer pricing in multinational enterprises. Journal of Accounting Education, 1-13.

Rossing, Martine, & Rohde. (2017). International transfer pricing in multinational enterprises. Journal of Accounting Education, 30(01), 01-13.

Schön, W., & Konrad, K. (2012). Fundamentals of International Transfer Pricing in Law and Economics. Verlag Berlin Heidelberg: Springer-.