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Thesis

French

ID: <

10670/1.989e8h

>

Where these data come from
Tax control of transfer prices and profit shifting

Abstract

Transfer prices can be defined generally, such as the prices associated with transfers of goods, services or intangibles between companies of the same group, located in different countries. They can be used as leverage to allocate or transfer to a particular group entity a greater or lesser share of the overall tax result and therefore subject these results to different tax rates. By fixing transfer prices, the groups play on their plates and influence the tax revenues of the states where they operate, which subsequently results in a shortfall for the state.In Morocco, transfer prices are almost always subject to adjustment during tax audits of subsidiary companies or branches or permanent establishments which are members of multinational groups. In fact, we observe that the tax administration tends to raise the taxable bases of taxpayers by significant amounts. The payment of "management fees", the payment of royalties or even the level of purchase prices of goods are thus frequently called into question by the tax administration within the framework of the procedures of verification of accounting.This article aims to propose a normative framework to reinforce the internal legislation and the fiscal framework of the transfer pricing policy in Morocco. Beginning with the inventory and the general context by assessing the current Moroccan tax legislation relating to transfer prices as well as the difficulties encountered in the context of control or verification missions proper. Thereafter, we will offer our detailed recommendations dedicated to the tax control of transfer prices in Morocco.

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