Practical Approaches to Resolving Transfer Pricing Disputes Arising from Non-Cash Transactions in Multinational Enterprises

This study examines how to resolve transfer pricing disputes involving non-cash transactions in multinational enterprises (MNEs), which are particularly challenging due to the lack of clear market benchmarks. Using qualitative juridical analysis and international case studies, it finds that robust, timely documentation supported by functional analysis is essential to reduce disputes. Effective strategies include advance pricing agreements, independent benchmarking and regulatory harmonization. The study highlights the need for flexible application of the arm’s length principle and alignment between business strategy and tax compliance, with implications for MNEs, tax authorities and future academic research.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2026-03-26
DOI
https://doi.org/10.59403/1dfr9x1
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

Practical Approaches to Resolving Transfer Pricing Disputes Arising from Non-Cash Transactions in Multinational Enterprises

Reza Adrinata
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

Practical Approaches to Resolving Transfer Pricing Disputes Arising from Non-Cash Transactions in Multinational Enterprises

Reza Adrinata
article en

Abstract

This study examines how to resolve transfer pricing disputes involving non-cash transactions in multinational enterprises (MNEs), which are particularly challenging due to the lack of clear market benchmarks. Using qualitative juridical analysis and international case studies, it finds that robust, timely documentation supported by functional analysis is essential to reduce disputes. Effective strategies include advance pricing agreements, independent benchmarking and regulatory harmonization. The study highlights the need for flexible application of the arm’s length principle and alignment between business strategy and tax compliance, with implications for MNEs, tax authorities and future academic research.

International Transfer Pricing JournalVol. 33(2)
Partnerships for the goals
Openalex Percentile: Top 7%
Corporate Taxation and Avoidance
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