Transfer Pricing Intensity in the European Union – Financial and Governance Determinants of High Intra-Group Transactions

This article investigates the key determinants of transfer pricing practices among EU companies. Using an integrated analytical framework, it examines how organizational structure, financial performance and corporate governance shape the volume of related-party transactions. The study relies on manually collected firm-level data, supported by Bloomberg and Thomson Reuters sources. A structured literature review identifies relevant variables, while logistic regression tests their influence. The results show that firms with high intra-group transaction volumes typically report lower effective tax rates, reduced profitability, limited operating cash flow, fewer intangible assets and smaller boards, highlighting patterns consistent with strategic transfer pricing behaviour.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2025-12-12
DOI
https://doi.org/10.59403/6rx68m
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

Transfer Pricing Intensity in the European Union – Financial and Governance Determinants of High Intra-Group Transactions

Renata Fulop
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

Transfer Pricing Intensity in the European Union – Financial and Governance Determinants of High Intra-Group Transactions

Renata Fulop
article en

Abstract

This article investigates the key determinants of transfer pricing practices among EU companies. Using an integrated analytical framework, it examines how organizational structure, financial performance and corporate governance shape the volume of related-party transactions. The study relies on manually collected firm-level data, supported by Bloomberg and Thomson Reuters sources. A structured literature review identifies relevant variables, while logistic regression tests their influence. The results show that firms with high intra-group transaction volumes typically report lower effective tax rates, reduced profitability, limited operating cash flow, fewer intangible assets and smaller boards, highlighting patterns consistent with strategic transfer pricing behaviour.

International Transfer Pricing JournalVol. 32(6)
Openalex Percentile: Top 45%
Corporate Taxation and Avoidance
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