Transfer Pricing and Income Shifting: Concepts, Pitfalls, and a Vision of the Future
为新手（包括从业者和学者）提供转让定价的基础知识，通过示例说明其不确定性，概述定价方法，并基于文献给出企业基准化转让定价的示例，最后展望未来。
SYNOPSIS Transfer pricing is a fundamental tool of multinational tax planning, but the outcomes of transfer pricing affect more than just tax professionals. The purpose of this perspectives article is to provide a layperson’s understanding of transfer pricing for those new to transfer pricing, including both practitioners and academics. Through an example we illustrate the fundamental uncertainty present in transfer pricing. We then provide an overview of transfer pricing methods and, drawing from the academic literature, provide an example that practitioners can follow to benchmark their firms’ transfer pricing efforts. Finally, we speculate on the future of transfer pricing. JEL Classifications: F23; H25; H26; H71.