Transfer Pricing Issues Related to the One-Belt-One-Road Project

Mirna Solange Screpante, Raffaele Petruzzi, Xue Peng, Vladimir Tyutyuryukov, Norbert Roller

Publikation: Beitrag in Buch/KonferenzbandBeitrag in Sammelwerk


The transfer pricing environment in OBOR countries is extremely diversified.
Most countries are in an early stage as regards the implementation of transfer pricing rules, while some others are much more advanced.1 This fact, despite constituting a disadvantage, might constitute also a great advantage, since reaching a common understanding on these topics would be easier. For example, countries such as Armenia, Azerbaijan, Bahrain, Brunei, Kuwait, Moldova, Syria, the United Arab Emirates and Uzbekistan do not have transfer pricing rules in their tax systems. For these countries transfer pricing rules might be seen as something complicated and costly to implement, but it should be born in mind that definitely the benefits are higher than the costs for two main reasons. First, protecting the tax base by domestic measures such as general or specific anti-avoidance rules might not be sufficient to the same extent than transfer pricing rules. Second, tax administrations might take different views on how to allocate profit among associated entities that could lead to double taxation (and, hence, a worst investment climate in the country). These rules, nevertheless, should balance, on the one hand, simplicity (where possible), certainty and clarity and, on the other, a fair and balanced taxation.
Titel des SammelwerksRemoving Tax Barriers to China’s Belt and Road Initiative
Herausgeber*innen Michael Lang Jeffrey Owens
ErscheinungsortThe Netherlands
VerlagKluwer Academic Publ.
Seiten169 - 196
PublikationsstatusVeröffentlicht - 2018

Österreichische Systematik der Wissenschaftszweige (ÖFOS)

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