This study examines how to resolve transfer pricing disputes involving non-cash transactions in multinational enterprises (MNEs), which are particularly challenging due to the lack of clear market benchmarks. Using qualitative juridical analysis and international case studies, it finds that robust, timely documentation supported by functional analysis is essential to reduce disputes. Effective strategies include advance pricing agreements, independent benchmarking and regulatory harmonization. The study highlights the need for flexible application of the arm’s length principle and alignment between business strategy and tax compliance, with implications for MNEs, tax authorities and future academic research.
Reza Adrinata (Thu,) studied this question.