Quotation Screpante, Mirna Solange, Petruzzi, Raffaele, Peng, Xue, Tyutyuryukov, Vladimir , Roller, Norbert. 2018. Transfer Pricing Issues Related to the One-Belt-One-Road Project. In: Removing Tax Barriers to China’s Belt and Road Initiative, Hrsg. Michael Lang Jeffrey Owens, 169-196. The Netherlands: Kluwer Academic Publ.




The transfer pricing environment in OBOR countries is extremely diversified. Most countries are in an early stage as regards the implementation of transfer pricing rules, while some others are much more advanced.1 This fact, despite constituting a disadvantage, might constitute also a great advantage, since reaching a common understanding on these topics would be easier. For example, countries such as Armenia, Azerbaijan, Bahrain, Brunei, Kuwait, Moldova, Syria, the United Arab Emirates and Uzbekistan do not have transfer pricing rules in their tax systems. For these countries transfer pricing rules might be seen as something complicated and costly to implement, but it should be born in mind that definitely the benefits are higher than the costs for two main reasons. First, protecting the tax base by domestic measures such as general or specific anti-avoidance rules might not be sufficient to the same extent than transfer pricing rules. Second, tax administrations might take different views on how to allocate profit among associated entities that could lead to double taxation (and, hence, a worst investment climate in the country). These rules, nevertheless, should balance, on the one hand, simplicity (where possible), certainty and clarity and, on the other, a fair and balanced taxation.


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Publication's profile

Status of publication Published
Affiliation WU
Type of publication Chapter in edited volume
Language English
Title Transfer Pricing Issues Related to the One-Belt-One-Road Project
Title of whole publication Removing Tax Barriers to China’s Belt and Road Initiative
Editor Michael Lang Jeffrey Owens
Page from 169
Page to 196
Location The Netherlands
Publisher Kluwer Academic Publ.
Year 2018
Reviewed? Y
Open Access N


Screpante, Mirna Solange (Former researcher)
Petruzzi, Raffaele (Details)
Peng, Xue (Former researcher)
Roller, Norbert (University of Applied Sciences Vienna, Austria)
Tyutyuryukov, Vladimir (University Higher School of Economics, Moscow,, Russian Federation)
Institute for Austrian and International Tax Law IN (Details)
Research areas (ÖSTAT Classification 'Statistik Austria')
5261 Comparative constitutional law (European -, international -) (Details)
5349 Business taxation (Details)
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