Tax Risk Management and Transfer Pricing: Practices and Evolutions

Stefano Venturini, prof.Guido Giovando
(Department of Management, University of Turin, Italy)

Abstract: The paper deals with Transfer Pricing and investigates the policies that MNEs undertake in order to manage the related risks. The recent implementation of the BEPS framework by many States around the globe tightened controls and compliance requirements of Tax Administrations. The Authors carried out a case study involving a Multinational Enterprise located in North-West Italy in order to assess how the recent evolutions are affecting internal procedures in the organizations. The first results are consistent with the contingency theory predicted in previous literature. Moreover, the case study shows that organizations are more compliance-oriented and see Transfer Pricing Practice as an operational lever to enhance their efficiency.

Key words: transfer pricing; tax risk management; OECD

JEL code: M1