Transfer pricing refers to the pricing of cross-border intercompany transactions. In the context of taxation, the main aim of transfer pricing is to share the income--and thus, the tax base--of multinational enterprises between the countries where they are doing business. The importance of transfer pricing has significantly expanded over the last few decades. With the globalisation of business activities, the need for States to monitor transfer prices so as to avoid the illegitimate erosion of their tax base, and the risk of double taxation faced by groups entering into intercompany transactions, transfer pricing has become a key question for multinational enterprises and tax.
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