Domestic Transfer Pricing: Global Neglect?

The transfer pricing (TP) landscape is dominated by cross-border transactions. This article discusses the relevance of domestic transfer pricing (DTP), including potential base erosion from interaction with cross-border transactions. The authors examine the interplay of DTP with GloBE rules and make suggestions for improving DTP regulations, based on an analysis of regimes around the world.

Authors

Publication Details

Journal
Bulletin for international taxation
Published
2025-03-11
DOI
https://doi.org/10.59403/11vbsyy
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

Domestic Transfer Pricing: Global Neglect?

Kuldeep Sharma, Suhash Kantamneni
Bulletin for international taxation
Corporate Taxation and Avoidance
article

Domestic Transfer Pricing: Global Neglect?

Kuldeep Sharma, Suhash Kantamneni
article en

Abstract

The transfer pricing (TP) landscape is dominated by cross-border transactions. This article discusses the relevance of domestic transfer pricing (DTP), including potential base erosion from interaction with cross-border transactions. The authors examine the interplay of DTP with GloBE rules and make suggestions for improving DTP regulations, based on an analysis of regimes around the world.

Bulletin for international taxationVol. 79(4)
Openalex Percentile: Top 94%
Corporate Taxation and Avoidance
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Domestic Transfer Pricing: Global Neglect? — Kuldeep Sharma, Suhash Kantamneni · Bulletin for international taxation (2025) | TGRS Research Map | TGRS