Domestic Transfer Pricing: Global Neglect?
- Kuldeep Sharma
- Mar 31
- 1 min read
IBFD, Netherlands has published an article on the captioned subject written by me and my friend Suhash.
The article highlights that the transfer pricing landscape is dominated by cross-border transactions with domestic intra-group transactions remaining largely under the radar. This is evident from extensive research of 123 jurisdictions, highlighting that only twenty-seven countries have promulgated detailed and specific Domestic Transfer Pricing (DTP) regulations.
Our research elucidates that DTP in certain jurisdictions is an outcome of judicial prompts with predominant focus on transactions undertaken amongst entities having tax arbitrage within a jurisdiction. Pertinently, with easy-to-understand examples, the paper underscores that DTP impacts cross-border pricing of transactions and all jurisdictions involved in the value chain.
The paper is expected to encourage administrations to draw inspiration to re-align their respective DTP rules in consonance with best global practices as well as include conditions and safe harbours to ameliorate compliance requirements of taxpayers. Not only this, the significant impact of DTP on GloBE Rules has been illustratively explained, which will enthuse academicians and administrators alike.
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