The article presents a comprehensive theoretical and methodological study of transfer pricing as a key instrument of corporate governance and state regulation in the field of foreign economic activity. It is shown that transfer pricing is a mechanism that integrates economic, managerial, and regulatory processes into a single system, forming the basis for effective interaction between enterprises and state institutions, and international regulators.The study substantiates the synergistic role of transfer pricing in the formation of an adaptive model of corporate governance, in which internal business decisions are aligned with external regulatory norms. It is revealed that through the use of transfer pricing, enterprises are able to optimally distribute functions, risks, and resources between structural units and group companies, which is a necessary condition for the effective management of global value chains. It is proven that transfer pricing acts as a mechanism for balancing the interests of participants in transnational processes.The article shows that the implementation of effective transfer pricing policies contributes to the minimization of tax, financial, and regulatory risks, increases the level of trust on the part of international partners, and strengthens the reputation capital of the enterprise in global markets. Particular attention is paid to the role of transfer pricing in tax planning, as its use allows enterprises to align their income and expense structures with international BEPS standards, while ensuring the efficiency of business processes and compliance with regulatory norms.The results obtained allow us to conclude that the synergy of corporate and state aspects of transfer pricing creates strategic advantages not only for individual companies but also for the development of the national economy as a whole.

This article presents a comparative analysis of transfer pricing as a regulatory mechanism for enterprises engaged in foreign economic activity across countries with diverse tax systems, including the United States, the United Kingdom, Germany, China, Poland, and Ukraine. Transfer pricing is shown to play a crucial role in ensuring financial transparency, mitigating tax risks, and aligning the conditions of cross-border transactions between related parties. The study examines the application of the arm’s length principle, documentation requirements, methods for determining market price ranges and profitability benchmarks, as well as dispute resolution mechanisms in different jurisdictions. Particular attention is given to Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) as key tools for minimizing double taxation and enhancing the predictability of tax outcomes for multinational enterprises.The comparative analysis reveals significant differences in regulatory approaches: the United States and the United Kingdom are characterized by methodological flexibility and robust APA programs; Germany demonstrates high efficiency in MAP procedures and a balanced evaluation of intercompany transactions; China adopts stricter control measures and primarily unilateral adjustments; Poland has intensified its regulatory framework, imposing substantial sanctions while expanding APA usage. Ukraine, currently undergoing tax system reform, is striving to harmonize with international standards but requires improvements in MAP procedures, APA implementation, and a more flexible approach to method selection.The findings support the development of policy recommendations aimed at strengthening Ukraine’s institutional framework for transfer pricing regulation. These include enhancing transparency in foreign economic operations, reducing tax-related risks, encouraging investment activity, and aligning national practices with OECD standards and BEPS initiatives.

Appraisal of Transfer Pricing in Nigeria and its Effect

This article examines transfer pricing not as a neutral technical mechanism for allocating costs and revenues, but as a strategic instrument used by multinational enterprises to engage in tax avoidance and consolidate wealth. Drawing on a critical accounting framework, it builds on Sikka and Willmott (2010), who show that intra-group pricing constitutes a politico-economic practice that enables the systematic shifting of profits to low-tax jurisdictions, thereby eroding the tax base of countries where real economic activity takes place. The analysis highlights how corporations mobilize technical legitimations such as claims of arm’s length pricing to construct new “truths” about fair value that are difficult for tax authorities to contest, particularly in developing countries with limited regulatory and audit capacity. Through a Foucauldian lens, transfer pricing is interpreted as a technology of power that reinforces the dominance of global capital over nation-states by controlling profit flows, structuring asymmetric regulatory negotiations, and deepening fiscal inequalities. The article thus argues that transfer pricing is a practice deeply embedded in vested interests and power relations, with significant implications for tax justice, state fiscal capacity, and the distribution of wealth in the global economy.

The significant transformation of agricultural production and operation models has reshaped the supply-demand structure of rural land, providing growth opportunities for new agricultural management entities characterized by large-scale operation. Their large-scale land demand has directly driven an upward trend in the transfer prices of contracted land management rights. By analyzing this practical phenomenon, this study explores the intrinsic logic behind the rising transfer prices of contracted land management rights under the participation of new agricultural management entities, aiming to provide references for further regulating the formation mechanism of transfer prices and promoting the healthy development of the land transfer market. Based on the sample survey data of farmers from the Songnen Plain and Sanjiang Plain in Northeast China, this study adopts the cluster-robust Ordinary Least Squares (OLS) model and moderating effect model for analysis. The results show that the participation of new agricultural management entities exerts a positive impact on the transfer price of contracted land management rights; the impact of new agricultural management entities’ participation on the transfer price is positively moderated by agricultural production efficiency; and the impact also presents heterogeneity across different villages and land parcels. Compared with remote villages and paddy parcels, the participation of new agricultural management entities has a more significant impact on the transfer price of contracted land management rights in township-adjacent villages and dryland parcels. Therefore, to reasonably standardize the transfer price of contracted land management rights, efforts should focus on further strengthening policy guidance to standardize the participation mechanism of new agricultural management entities, regulating the transfer market to establish a dynamic monitoring mechanism for transfer prices, and strengthening the training and guidance for new agricultural management entities to connect and drive farmers so as to improve the agricultural production efficiency of individual farmers.

This study aims to examine the effect of capital intensity and transfer pricing on tax avoidance, as well as the role of institutional ownership as a moderating variable in these relationships. The object of this study consists of companies in the mining sector listed on the Indonesia Stock Exchange (IDX) during the period 2020–2024. Based on purposive sampling, 50 companies were obtained as samples which produced 250 research data. Data analysis was conducted using moderated regression analysis with an interaction test approach. The results indicate that, partially, both capital intensity and transfer pricing do not have a significant effect on tax avoidance. However, simultaneously, these two variables have a significant influence on tax avoidance. Furthermore, the study finds that institutional ownership moderates the relationship between capital intensity and tax avoidance, indicating that institutional investors may strengthen or weaken this relationship through their monitoring role. On the other hand, institutional ownership does not moderate the relationship between transfer pricing and tax avoidance. This study offers important implications for corporate management, regulators, and investors to consider the interaction between internal factors when addressing and managing tax avoidance behavior.

The study was conducted with the aim of analyzing the influence of transfer pricing, return on assets, leverage, firm size, and tax haven on income shifting (an empirical study of energy sector companies listed on the Indonesia Stock Exchange from 2019-2022. The method used a quantitative method with an explanatory research type. The populations selected of the study are all Energy Companies listed on the IDX from 2019-2022 by totaling 75 Companies. The sampling technique of the study used a purposive sampling technique. The data analysis method used panel data with the Eviews software program version 10. The study found that transfer pricing has no effect on income shifting, return on assets has effect on income shifting, leverage has effect on income shifting, firm size has effect on income shifting, and tax haven has effect on income shifting in energy sector companies listed on the IDX for the period 2019-2022.

The study was conducted with the aim of determining the impact of intangible assets and audit quality on transfer pricing practices in Multinational Companies listed on the IDX for the 2020-2024 Period of the Consumer Non-Cyclicals Sector. The research method used was multiple regression analysis. The results of the study showed that there was a partial positive influence by the intangible asset variable on transfer pricing but there was no partial effect by the audit quality variable on transfer pricing. The results of the study also show that there is a simultaneous influence of the intangible asset variable and audit quality on transfer pricing.

Reforming tax policies: foreign ownership and transfer pricing strategies

This study analyzes the relationship between profitability (ROA), transfer pricing (measured by the related-party receivables ratio), and financial statement fraud (assessed using the Beneish M-Score and Dechow F-Score) and the dependent variable, tax avoidance (CETR). Additionally, it examines the moderating role of the tax burden index. It adopts a descriptive quantitative design, utilizing secondary financial data from energy and mining companies listed on the Indonesia Stock Exchange over the period 2019 to 2023. Of all companies listed on the stock exchange, only 15 companies met the criteria of complete and consistent financial data during the observation period, yielding 75 firm-year observations. The results show that financial statement fraud significantly affects tax avoidance (β = -4.38e-14, p = 0.0030), while profitability (β = -1.247, p = 0.4835) and transfer pricing (β = 0.635, p = 0.3565) do not show significant effects. Furthermore, the tax burden index does not moderate the relationship between transfer pricing and tax avoidance (β = 4.386, p = 0.7947). These findings emphasize that behavioral factors, particularly profit manipulation, play a more dominant role than traditional financial indicators in driving tax avoidance. The implications of this study underscore the importance of strengthening corporate internal control mechanisms, improving financial reporting transparency, and ensuring tax compliance through effective regulation. The energy and mining sectors, which are at high risk of manipulative practices, require special attention so that tax avoidance practices can be minimized, fiscal justice supported, and the integrity of the overall taxation system strengthened.

The present research examines how tax burden, company size, and foreign ownership influence transfer pricing decisions in manufacturing firms registered on the Indonesia Stock Exchange between 2020 and 2024. Data analysis employed a quantitative method, processed using the Eviews 13 application. This study analyzed 156 observations using unbalanced panel data regression through a fixed effect approach. The results showed that tax burden and company size significantly influenced transfer pricing decisions, while foreign ownership did not. This study revealed that transfer pricing decisions were significantly influenced by tax burden and company scale. This can be explained within the framework of agency theory, where managers attempt to minimize tax burdens to enhance the company’s performance from the owners' perspective, even though this step may lead to tension with tax authorities. In addition, this finding aligns with signaling theory, as transfer pricing practices can be viewed as a sign of management's ability to manage taxes efficiently, particularly in large companies that receive more scrutiny from external parties.

This article investigates the key determinants of transfer pricing practices among EU companies. Using an integrated analytical framework, it examines how organizational structure, financial performance and corporate governance shape the volume of related-party transactions. The study relies on manually collected firm-level data, supported by Bloomberg and Thomson Reuters sources. A structured literature review identifies relevant variables, while logistic regression tests their influence. The results show that firms with high intra-group transaction volumes typically report lower effective tax rates, reduced profitability, limited operating cash flow, fewer intangible assets and smaller boards, highlighting patterns consistent with strategic transfer pricing behaviour.

This article explains how “debt capacity” is a crucial concept in transfer pricing, determining the maximum amount of intercompany debt that aligns with what independent parties would agree under market conditions. It highlights the need for both quantitative financial analysis and qualitative assessment to ensure intercompany loans are respected as debt and not reclassified as equity for transfer pricing purposes.

Transfer pricing represents a strategic element within multinational enterprises as it lies at the intersection of tax compliance, cost management systems, and the interests of multiple stakeholders. This study synthesizes findings from ten selected journals that examine the determinants of transfer pricing, the methods used to establish transfer prices, and the implications for taxation and corporate governance. The synthesis reveals that firm size, foreign ownership, leverage, and tunneling incentives are the most consistent factors influencing transfer pricing practices. From a managerial perspective, the Activity-Based Costing (ABC) method enhances the accuracy of transfer price determination compared to traditional costing approaches. Meanwhile, from a taxation standpoint, the application of the arm’s length principle through the Comparable Uncontrolled Price (CUP), Cost Plus, and Profit Split methods remains the most relevant approach to minimizing the risk of cross-border tax disputes. This study concludes that achieving balance among tax regulations, appropriate cost management systems, and effective corporate governance mechanisms is crucial for ensuring that transfer pricing practices are conducted fairly, transparently, and accountably.

This article examines a recent Belgian court case on captive reinsurance, highlighting the importance of control over risk in determining transfer pricing outcomes. The court ultimately found that the Swiss captive reinsurer exercised sufficient control over risk and that the premiums it received were at arm’s length, setting a precedent for the importance of a thorough risk analysis and evidentiary standards in transfer pricing disputes.

The purpose of this study is to analyze the influence of the audit committee, transfer pricing, and political connections on tax avoidance in manufacturing companies within the food and beverage sub-sector listed on the Indonesia Stock Exchange during the 2021–2023 period. This research employs a quantitative method with a descriptive approach and multiple linear regression analysis. The data used consist of secondary data obtained from the financial statements of 15 companies over three years of observation, resulting in a total of 45 observations. The results reveal that the audit committee and political connections have no significant effect on tax avoidance, while transfer pricing has a positive and significant effect. These findings suggest that transfer pricing remains the primary strategy used by companies to minimize their tax burden, whereas the effectiveness of the audit committee and political connections in curbing such practices has yet to be optimized. In conclusion, strengthening the supervision of transfer pricing policies and enhancing the role of the audit committee are essential to promote transparency and improve tax compliance among manufacturing companies. Keywords: audit committee, transfer pricing, political connections, tax avoidance

The purpose of this research is to empirically test and obtain evidence regarding the influence of Thin Capitalization and Transfer Pricing on Tax Avoidance, moderated by Financial Constraints. This study uses a sample of non-cyclical consumer sector companies listed on the Indonesia Stock Exchange (IDX) from 2019 to 2023 The sampling technique employed is purposive sampling, where from 130 non-cyclical consumer sector companies, a sample of 25 companies was obtained over 5 years, resulting in a total of 125 data samples. The analysis used is panel data regression analysis employing a fixed effect regression model for equations I and II. The data was processed using Eviews12 software. The results indicate that both thin capitalization and transfer pricing simultaneously influence tax avoidance. The findings also show that, partially, thin capitalization affects tax avoidance, and transfer pricing affects tax avoidance. Additionally, the results indicate that financial constraints do not moderate the influence of thin capitalization, while financial constraints do moderate the influence of transfer pricing on tax avoidance.

This study examines transfer pricing taxation in Japan with a focus on the use of comparable uncontrolled transactions (CUP) and the adjustment of differences. While the OECD Transfer Pricing Guidelines (2017) and Japan’s 2011 reform introducing the “best method rule” have provided a clearer framework, practical challenges remain in securing true comparable and conducting reliable adjustments. To address this issue, the paper analyses the Brazil Honda case, structuring the discussion around key issues, legal reasoning, and judicial conclusions. The case illustrates how factors such as government regulation, market conditions, and location savings influence comparability and the determination of the arm’s length price. The findings highlight the necessity of rigorous comparability analysis to ensure fairness and predictability in taxation. This study contributes by bridging the gap between institutional principles and practical implementation, offering implications for policymakers, tax authorities, and multinational enterprises.

From 2020 to 2023, this research looks at food and drink manufacturing businesses listed on the Indonesia Stock Exchange to see how transfer pricing is affected by good corporate governance, bonus mechanisms, and tunneling incentives. Purposive sampling was used to choose data from consolidation financial reports, which were then analyzed using multiple linear regression. According to the results, Good Corporate Governance considerably decreases Transfer Pricing, suggesting that executive discretion is limited by independent supervisory scrutiny. It seems that performance-based incentives are not the main factor driving Transfer Pricing, since Bonus Mechanisms have a positive but negligible influence. At the same time, Tunneling Incentives) cut down on Transfer Pricing, which means that more oversight and less such tactics are possible with more foreign ownership. The analyzed variables good corporate governance, bonus mechanism and tunneling incentive all show significant correlations with Transfer Pricing, according to the correlation analysis. With an Adjusted R Squared value of 0.266, the model suggests that the variables under investigation account for 26.6% of the variation in Transfer Pricing, while other, unexplored factors contribute to the remaining 73.4%

This study was conducted to determine the effect of tax burden, tax planning, and tax havens on transfer pricing in food and beverage manufacturing companies listed on the Indonesia Stock Exchange in 2022-2024. The population in this study was all food and beverage manufacturing companies listed on the Indonesia Stock Exchange in the 2022-2024 period. The data analysis technique used SPSS. The results of the study indicate that tax burden has an effect on transfer pricing in food and beverage manufacturing companies listed on the Indonesia Stock Exchange in the 2022-2024 period. Tax planning has no effect on transfer pricing in food and beverage manufacturing companies listed on the Indonesia Stock Exchange in the 2022-2024 period. Tax havens have no effect on transfer pricing in food and beverage manufacturing companies listed on the Indonesia Stock Exchange in the 2022-2024 period.