دور أسعار التحويل في التهرب الجبائي الدولي : دراسة حالة سويسرا لوكسمبورغ بنما هونكونغ

Abstract

The study aimed to highlight the role of transfer rates in international tax evasion as a global phenomenon, suffered by most countries, in order to avoid being used by companies as a means of tax evasion. In this study, we identified the legal and economic significance of the conversion rates, and also the main revenues that the tax legislator makes in this field. We used the analytical meta method The study indicated that conversion rates were of interest and value to the company for controlling performance and profits, on the one hand, and on the other, were a means of international tax evasion. Thus, double taxation agreements have emerged to avoid or reduce this phenomenon, as it plays a pivotal role in international cooperation in the tax field. The study found that transfer rates encourage international investment. It promotes cooperation between tax administration, especially with regard to fraud a nd international tax evasion, which is manifested by countries competing to attract capital and apply tax concessions. However, it is considered a means to reduce taxable profits, and thus tax evasion