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Transfer Pricing Audit Challenges and Dispute Resolution Effectiveness in Developing Countries with Specific Focus on Zimbabwe

Base erosion and profit shifting activities of multinational enterprises (MNEs) have been a hot issue globally. Topical among the strategies employed by MNEs has been the issue of transfer pricing (TP). Developing countries are argued to be significantly affected by TP manipulation resulting in substantial tax revenues being lost. As a response to curb the unfavourable impacts of transfer mispricing, most developing countries have adopted the OECD TP guidelines and enacted TP legislation to regulate TP activities. The arm’s length principle is the core of TP legislation, yet it has brought challenges for tax administrators and their auditors in enforcing and assessing compliance respectively leading to disputes. In view of the ever-changing business world and continuous efforts by MNEs to minimise their tax obligations through income shifting, it was imperative to assess the factors affecting the effectiveness of TP audits and dispute resolutions as measures to enhance compliance and enforcement in developing countries, with specific reference to Zimbabwe. Findings include the lack of clarity in TP legislation, resource constraints and complexity of transactions, lack of expertise as well as the shortage of comparable data. Developing countries are encouraged to formulate clear TP regulations and invest in the capacitation of revenue authorities.

Appendix A: Interview Guide

Zimbabwe has recently introduced new transfer pricing rules, outline the TP regulatory system in Zimbabwe and how you have applied it.

How feasible has been the enforcement process of the TP legislation? What challenges have you encountered?

What are the dispute resolution procedures in the case of a transfer pricing adjustment in Zimbabwe?

How effective are these dispute resolution procedures?

How often do you conduct TP audits?

How effective are the TP audits?

What challenges are encountered in the auditing of TP transactions and in resolving disputes while applying the TP rules?

ZIMRA plays a vital role in the detection and oversight of transfer pricing abuse. How effective is ZIMRA in discharging its duties in relation to transfer pricing?

Appendix B: Interviewee Profiles

Summary of Interviewee profiles

NB* All the Tax Consultants were Zimbabweans, two of them currently working for tax departments in Accounting firms outside Zimbabwe (Botswana and South Africa). Four of the Tax consultants have had a chance to be attached to South African Revenue Services and one with the Kenyan Revenue Services to learn more on transfer pricing.

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Journal of Accounting & Organizational Change

ISSN : 1832-5912

Article publication date: 26 August 2014

The purpose of this paper is to critically review the empirical transfer pricing literature as a means of determining the agenda for future research.

Design/methodology/approach

The review is carried out primarily by searching databases, academic journals and books. Second, professional surveys are reviewed to inform the development of research ideas.

The understanding and ability to explain international transfer pricing in practice remain limited despite a rapidly increasing tax regulatory pressure on multinational enterprises. One important explanatory factor is that accounting and tax research has not been integrated to a sufficient extent. As a consequence, rather isolated research streams and knowledge building have taken place, failing to leverage the synergies of a combined research approach.

Research limitations/implications

A stronger emphasis on the outcome of specific transfer pricing system designs would improve the literature’s current status in terms of whether the objectives aimed at by the system are actually achieved. A new framework and promising research questions are proposed to guide future work on this issue.

Practical implications

The proposed framework may serve as guidance for practitioners seeking to assess the performance of specific transfer pricing systems and potentially provide directions for refinement of current system designs when dysfunctional consequences are identified.

Originality/value

Previous transfer pricing research has taken a rather isolated approach. This paper is an attempt to guide future transfer pricing research towards an inter-disciplinary approach.

• Performance measurement
• Transfer pricing
• Management control systems
• Accounting change
• Accounting in global corporations and less developed countries
• Cost and managerial accounting

Acknowledgements

The authors wish to thank Trond Bjørnenak, Stan Brignall, Martine Cools, Jesse Dillard, Jytte Larsen and Hanne Nørreklit, as well as other participants at a research seminar at SCANCOR, Stanford University (March 2010), for their helpful and constructive comments on previous versions of this paper. Finally, the authors would like to thank two anonymous reviewers and the Editor Zahirul Hoque for their constructive and useful comments. Funding provided by The Danish Institute of State-Authorized Public Accountants (“FSRs Studie- og Understøttelsesfond”) is greatly appreciated.

Plesner Rossing, C. and Rohde, C. (2014), "Transfer pricing: aligning the research agenda to organizational reality", Journal of Accounting & Organizational Change , Vol. 10 No. 3, pp. 266-287. https://doi.org/10.1108/JAOC-03-2012-0017

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• DOI: 10.31963/akunsika.v5i2.4761
• Corpus ID: 271499237

The Effect of Transfer Pricing, Book Tax Difference and Thin Capitalization on Tax Avoidance Practices

• Rachelle Elishang , Muhammad Fahmi , Rudy Kurniawan
• Published in AKUNSIKA: Jurnal Akuntansi… 30 June 2024
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What makes transfer pricing an important issue for growing life sciences businesses?

24 september 2024.

Building a successful life sciences business is a complex journey. It involves:

• Successfully conducting the research and development needed to build a strong and compelling product or service proposition.
• Developing a strong commercial model and market proposition.
• Navigating the regulatory environment – for example, through clinical trials and obtaining the right marketing authorisations.

All this usually needs to be achieved while managing tight funding constraints.

International expansion is also an important part of the growth journey for many life sciences businesses. For some, this will come at the pre-revenue stage. A common example is where the business recruits valuable talent in other countries, a seemingly simple step which can have wide-ranging consequences. For others, international expansion comes as they commercialise and look to sell into other markets. This will often mean an expansion into the US, the world’s largest healthcare market. Since Brexit, it has also become more common for UK life sciences businesses to establish a European entity as an entry point for sales into EU markets.

Compared to businesses in other sectors, this means that life sciences businesses often expand internationally while they are still at an earlier point in their lifecycle and getting that expansion right is especially fundamental to their long-term commercial success.

Why is transfer pricing important to this journey?

Transfer pricing is an internationally agreed approach to working out how profits (or losses) should be recognised across a group. At its heart is the arm’s length principle. Its core idea is that each member of a group entity should earn a similar profit (or loss) to an independent business performing the same role on a similar basis under comparable conditions. There are five specific transfer pricing methods by which this can be achieved, but we’ll focus in this article on the outcome – the profit distribution across the group.

If the transfer pricing is not correct in the accounts, it is usually only possible to adjust the profits of the entity that earned too little profit (or made too big a loss) via the tax return. This typical ‘one-sided’ approach to tax return adjustments means that the same amounts can be taxed twice, consuming valuable additional cash.

Although transfer pricing is a tax concept, the policy adopted often shapes the statutory accounts and financial records across a group. It is also fundamental for accurate profit forecasting of the long-term profit distribution and profit profile across the business.

There can be exemptions from the transfer pricing rules for small businesses or small transactions but, unfortunately, there is no consistent approach internationally. For example:

• The UK has a test based on the group’s employees, revenues and balance sheet.
• Other territories may use thresholds based on consolidated group revenues or transaction values.
• Some countries, like the US, do not offer any exemptions.

For those businesses that do come under scrutiny, enquiries often run for several years , which can place significant strain on management time and resource.

Transfer pricing is also commonly examined as part of a due diligence exercise if the business is sold at a later date. While transfer pricing is not usually a deal breaker, a weak transfer pricing model or gaps in the support for it can lead to price chipping.

Not considering transfer pricing at the right time can also have wider consequences. This can sometimes be the case even where the business has expanded into countries whose local transfer pricing rules do not apply yet. Examples of these wider consequences can include:

• Trapped cash.
• Unintended intercompany balances with the character of loans.
• The establishment of broader long-term fact patterns which materially increase the risk of future challenge by the local tax authority. One specific example would be a local subsidiary which runs at a loss but performs a role for which some level of profit would be expected.

All of this means that the practical answer is often simply to get the group’s transfer pricing right at an early stage.

What key factors make for a strong transfer pricing position?

A strong transfer pricing position plays an important role in managing these risks. It has many elements, but there are five key areas that are particularly important for growing life science businesses:

• A clear, robust transfer pricing policy position: this should closely follow how your business actually works in practice so that the profits (or losses) are distributed accordingly. Your Intellectual Property (IP) is a particularly important part of this picture, since the transfer pricing rules place significant weight on the key decision-making roles related to IP when deciding where the profits associated with that IP should be taxed.
• Robust implementation: the key parameters for the transfer pricing model should be clear (and typically, recorded in a legal agreement) and carefully followed in practice.
• Accurate calculation and invoicing: invoices need to be issued for accurately calculated amounts and with a robust audit trail to your business and financial records.
• Documentation: you need to be able to explain why your transfer pricing model works the way it does – for example, to respond to a tax enquiry but also for any future due diligence on a sale of the business.
• Monitoring: your transfer pricing model needs to be kept up-to-date. Put simply, if your business changes, your transfer pricing may well need to change too.

How our transfer pricing experts can help your life sciences business

We have an experienced network of transfer pricing specialists in the UK and across our global network. These specialists work closely with a wider team of industry experts to provide our clients with tailored support based on their individual business and expansion plans.

To discuss transfer pricing for your life sciences business, please contact Graham Bond, Paul Minness or Matt Sims.

• Transfer pricing
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• Life sciences
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An improved transfer learning algorithm using integration method and its application in image segmentation and recognition

• Published: 25 September 2024

Cite this article

• Yuchong Chen 1 ,
• Xi Fang 1 &
• Hua Han 1  

Images find frequent applications in numerous fields, such as healthcare and aerospace, and the demand for image recognition and classification is continually rising. Currently, research on image classification is primarily conducted within the realm of big data, where ample training images are available. However, in scenarios where image data acquisition is challenging, most studies rely on a single transfer learning model for experimentation. Building upon the examination of multiple transfer learning models, this paper delves into fusing these models and further exploring their optimization strategies. The findings reveal that in datasets with limited data, involving too many unfrozen convolution layers in weight updates can lead to overfitting in the transfer learning model. Conversely, fine-tuning only the fully connected layers achieves better training outcomes. The research outcomes indicate that the Stacking fusion model plays a pivotal role in enhancing model accuracy. Compared to VGG16, ResNet, and Inception V3, the fusion model exhibits accuracy improvements of 11.11%, 35.40%, and 20.64%, respectively. Furthermore, by substituting the InceptionV3 model with the DenseNet model and replacing the secondary classifier with the XGBoost algorithm, the overall model accuracy was further boosted by 3.65%, while the time consumption was reduced by 11.20%. The novelty of this paper lies in its utilization of the Stacking model fusion approach to integrate and optimize transfer learning models, thereby exploring avenues to enhance the ultimate performance of the model.

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Acknowledgements

First of all, I would like to express my gratitude to Professor Xi Fang and Professor Hua Han for guiding my paper writing. Your explanations and patient guidance on the project have been constantly guiding me, helping me complete one difficult task after another. Your kind personality has finally helped me overcome my fear of communicating with teachers. When I encountered difficulties in my research, your encouragement always gave me confidence and the courage to continue challenging. Your teachings on me will continue to inspire me in my future research and even in my life, making me a better version of myself. Secondly, I also want to thank my parents and relatives. Your care and love for me are a powerful driving force for me to move forward, and my greatest wish is for you to always be healthy and happy. Lastly, I would like to express my gratitude to my friends who have always been by my side. Thank you for your companionship and encouragement, as well as for all the friends who have helped me during my writing process. It is because of you that I am able to continuously strive forward on the path of scientific research.

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Chen, Y., Fang, X. & Han, H. An improved transfer learning algorithm using integration method and its application in image segmentation and recognition. Multimed Tools Appl (2024). https://doi.org/10.1007/s11042-024-20290-z

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Received : 04 August 2023

Revised : 18 July 2024

Accepted : 11 September 2024

Published : 25 September 2024

DOI : https://doi.org/10.1007/s11042-024-20290-z

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