The article “Cross-Border Transactions vis-à-vis Transfer Pricing and Double Taxation” examines the complex interplay between cross-border transactions, transfer pricing, and double taxation, highlighting the challenges multinational businesses face when operating across jurisdictions where tax authorities in different countries may seek to tax the same income. It further discusses the role of transfer pricing regulations, the arm’s-length principle, and Double Taxation Avoidance Agreements (DTAAs) in ensuring fairness, transparency, and compliance in international business arrangements.
The article emphasises that while cross-border business models are essential to the global economy, they must be structured with careful attention to tax regulatory requirements, as transfer pricing and double taxation remain key areas of scrutiny for tax authorities worldwide. It also underscores the importance of maintaining robust documentation, adopting transparent pricing mechanisms, and ensuring compliance with applicable treaty frameworks to mitigate tax disputes and regulatory risks.
