• State as a Minority Shareholder: Rethinking Transfer Pricing Profit Allocation Under Pillar 2

    Against the backdrop of the newly introduced 15% global minimum corporate tax under Pillar 2, this article explores whether—and how—the contribution of individual states to multinational profits could be more transparently reflected in transfer pricing outcomes. It proposes a conceptual shift: viewing the state not merely as a tax authority, but as a form of…

  • From Hierarchy to Harmony: The Transfer Pricing in Turquoise Organizations

    From Hierarchy to Harmony: The Transfer Pricing in Turquoise Organizations A turquoise organization, by definition, moves away from the traditional hierarchical structure. It eliminates the typical layers of management, fixed job roles, and rigid staffing arrangements. Decentralization, transparency, and customer-centricity have become so deeply ingrained in everyday business that they can be seen everywhere—from coffee…

  • Transfer pricing research: Is there an alternative manual sample?

    The most part of researches of the profit market range of efficiency is construction on selection of financial performance in the financial reporting, a code of a type of activity NACE Rev.2 of the company and its activity on the Internet. [1] Does this approach give real market range or only a part of it?