This dissertation
was written as part of the MSc in International Accounting, Auditing
and Financial Management at the International Hellenic University.
For at least two decades transfer pricing has become more and more challenging to
both
multinational enterprises
and ta
x authorities. In case of the multinational enterprises,
in
planning
and
implementing
their
global
operations
due
to
the globalized world economy
, since they have to comply with laws and administrative
requirements that may differ from country to country
.
In case of tax administrations,
specific problems arise at both policy and practical levels.
In the context of this dissertation project is going to be presented
how the OECD
Transfer
Pricing
Guidelines
for
Multinational
Enterprises
and
Tax
Administrations
and local Transfer Pricing rules affect the pricing of intra
group
transactions. A relevant example from Oil and Gas Industry has been used in order to
give a better understanding on how these rules apply.
A company and an industry analysis provide details
for the company and the whole
environment in which the company operates. Further on, the intragroup transactions
are being presented along with a functional analysis in order to identify factors that
affect the aforementioned transactions. Afterwards, the
relevant legislation is
presented and
Transfer Pricing methods are outlined.
Subsequently
, in the economic
analysis, the most appropriate transfer pricing method is selected in order to evaluate
whether or not the intragroup transactions are within the arm’s length range
.
Finally, an overall conclusion is drawn on how Transfer Pricing rules can be used to
examine the appropriateness of the taxable base of an entity that engages in intragroup
transactions through the examination of its profitability with the use of the applicable
methods.
All
data used, was
from Amadeus database
as well as from the financial statements of
LPC S.A
.
Additional information was obtained from the
OECD Guidelines for
Multinational Enterprises and Tax Administrations
. Moreover,
information from
the
international and domestic press and scientific websites.
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