ÀÏ˾»úÎçÒ¹¸£Àû

General principles

Transfer pricing tax rules exist to counter the opportunity for groups to reduce their global tax burden by shifting profits to low tax jurisdictions through group pricing, eg by selling goods at cost from a company in a higher tax jurisdiction to one in a lower tax jurisdiction. Without tax rules to counter this, the company in the lower tax jurisdiction would make higher profits through its lower cost of sales. The company in the higher tax jurisdiction