فعالية التشريعات الضريبية الوطنية و الاتفاقيات الدولية في ضبط أسعار التحويل في الجزائر

Abstract

"This study aims to shed light on transfer pricing as a contemporary tax issue of significant importance, by clarifying its fundamental concepts and its economic and fiscal significance, reviewing the main methods adopted for determining transfer prices, and analyzing the national and international legal framework governing them. It also seeks to examine the extent to which Algerian tax legislation aligns with international standards, particularly the guidelines of the Organisation for Economic Co-operation and Development (OECD), and to assess the effectiveness of the tax control mechanisms related to transfer pricing in Algeria. The study relied on the descriptive-analytical method, alongside a field study using a questionnaire administered to a sample of specialists and individuals interested in the tax and accounting field. The results showed that the sample members are aware of the importance of transfer pricing and its impact on the tax base and the effectiveness of tax control. They also confirmed that Algerian tax legislation plays a role in regulating transfer pricing, while highlighting the need to strengthen the effective implementation of legal and control mechanisms. Furthermore, the results revealed the importance of international tax treaties in supporting tax cooperation, information exchange, and curbing profitshifting practices, and showed that integration between national legislation and international agreements is a key factor in enhancing the effectiveness of transfer pricing regulation and improving tax control."