book chapter
Transfer pricing forms a critical component of international tax governance as multinational enterprises expand and emerging economies increase regulatory scrutiny. An evaluation spanning India, China, Brazil, South Africa, and Indonesia assesses national accounting systems and regulatory frameworks alongside OECD standards and Base Erosion and Profit Shifting initiatives. Compliance faces growing complexities stemming from intangible assets, digital developments such as artificial intelligence, big data, and blockchain, and environmental, social, and governance transparency demands. To tackle these issues, the proposed Integrated Transfer Pricing Compliance Framework links OECD guidelines, accounting standards, governance structures, digital tools, risk management, documentation, and compliance monitoring. The framework aims to bolster tax transparency, regulatory consistency, and sustainable tax administration across emerging markets.
As multinational business expands across emerging economies, aligning cross-border commercial transactions with international tax rules grows increasingly difficult. Implementing coherent compliance frameworks helps reduce cross-border regulatory friction, aids tax administrations in preventing profit shifting, and ensures emerging economies can maintain stable tax revenues amid rapid digitalization and evolving governance standards.
The conceptual framework could guide compliance system design for corporate tax departments, advisory firms, and revenue authorities handling cross-border operations in emerging markets. It outlines how digital tools, risk management, and ESG factors can be embedded into reporting processes. As an academic model, it sits at an early stage of development and would require translation into software workflows or enterprise compliance programmes before practical use.
AI-generated from the published abstract. Always read the original work before citing.
Transfer pricing has become a key element of international tax governance as multinational enterprises expand globally and emerging economies strengthen regulatory oversight. This chapter examines transfer pricing compliance by integrating the OECD Transfer Pricing Guidelines with national accounting systems in India, China, Brazil, South Africa, and Indonesia. It reviews the conceptual foundations of transfer pricing, analyzes the OECD framework and BEPS initiatives, and compares accounting and regulatory practices across these economies. The chapter also discusses compliance challenges related to digitalization, intangible assets, artificial intelligence, big data, blockchain, and ESG-driven tax transparency. Its main contribution is the proposed Integrated Transfer Pricing Compliance Framework (ITPCF), which integrates OECD guidelines, accounting standards, governance, digital technologies, risk management, documentation, and compliance monitoring to improve tax transparency, regulatory consistency, and sustainable tax governance in emerging markets.
This page summarises published work. The authoritative version sits with the publisher.
DOI: 10.4018/979-8-2600-0020-5.ch007
Is something wrong with this record? Report it or request removal.
Discussion
Have you built on this work, tried to replicate it, or seen it applied in practice? Share what you know. Verified researchers and MARATTO™ domain experts can open a discussion, and any member can reply. Contributions are reviewed before they appear.
No discussion yet. Open the first thread.
New to MARATTO™? Create a free account.
