Transfer pricing regulations worldwide: a survey

Laudage Teles, Sabine / Valeria Merlo / Nadine Riedel / Kristina Strohmaier
Externe Publikationen (2024)

RSIT Working Paper 04/2024, Tübingen: Eberhard Karls Universität/Research School of International Taxation

Transfer pricing (TP) regulations have been introduced in the domestic tax laws of 177 countries by the year 2019. This paper provides a survey on TP regulations worldwide for the years 2001 to 2019. First, the paper  provides a descriptive overview on the dataset, which includes variables on the years of introduction of TP regulations as well as 40 variables on different provisions in TP regulations. We then perform a pooled cluster analysis on our TP panel dataset to find out how TP regulations have evolved across countries and over time. Finally, we analyze the determinants of bilateral dissimilarity in TP regulations across countries and over time in a regression framework. We find that bilateral trade and income levels are explain similarity in TP regimes across countries. Other geographic and cultural proximity indicators also play a significant role.