OECD transfer pricing guidelines multinational enterprises and tax administrations (2010 edition) and transfer pricing features of selected countries 2013. Aurobindo Ponniah ; Antoine Glaize.
The increase in global trade and foreign direct investment has seen a large rise in companies operating across national borders. The growth of these multinational companies (MNCs) has been closely followed by the issue of inter-company transfer prices being used to reduce taxable profits. Today, transfer pricing is one of the most important issues facing MNCs as they attempt to fairly distribute their profits amongst each company in the group while dealing with tax authorities who are implementing transfer pricing regulations and strengthening enforcement in order to prevent a loss of revenue. The result of which is that transfer pricing controversies have become a major tax issue for companies.