Deparment of Economics
Library of the Faculty of Economics and of the Faculty of Business Administration

2021-08-05

2021

Tzavaras Marios

Ηρειώτης Νικόλαος, Καθηγητής ΕΚΠΑ
Βασιλείου Δημήτριος, Καθηγητής ΕΚΠΑ
Ντόκας Ιωάννης, Επίκουρος Καθηγητής ΔΠΘ
Γκούμας Σπυρίδων, Καθηγητής ΠΑΔΑ
Καλαντώνης Πέτρος, Αναπληρωτής Καθηγητής ΠΑΔΑ
Κώτσιος Στυλιανός, Καθηγητής ΕΚΠΑ
Μπάλιος Δημήτριος, Αναπληρωτής Καθηγητής ΕΚΠΑ

Εφαρμογή και διενέργεια πρότυπου μοντέλου ενδοομιλικών συναλλαγών στην ελληνική επικράτεια : διαχείριση της φορολογητέας ύλης των συνδεδεμένων επιχειρήσεων μέσω των ενδοομιλικών συναλλαγών τους

Greek

Procedure and implementation of transfer pricing model in Greece : manipulation of taxable income through transfer pricing in intragroup transactions

The present thesis examines the tax incentives related to pricing decisions between MNC affiliated companies that are tax residents in Greece and focuses on the intragroup transfer pricing between related parties. In the empirical part of the thesis, it is assessed whether the affiliated companies, through intragroup transactions, shape their taxable income according to the tax rate applied in each case.
The sample of this empirical study was retrieved from the Amadeus (Analyze MAjor Databases from EUropean Sources) Tp-Catalyst (TP 96, March 2018 edition) database and consists of 2,131 companies from almost all sectors of the Greek economy, of which 971 are independent, and 1,160 are affiliated with multinationals. The total sample consists of 17,048 observations, of which 7,768 refer to independent and 9280 to affiliated companies and covers the years from 2010 to 2017.
For the empirical analysis, descriptive statistics, hypothesis testing and regression analysis were performed for panel data, with an autoregressive vector error correction model (VECM) with two lags.
The results of the study are generally in compliance with the international literature. According to the study, affiliated companies appear to have lower profit margins, lower tax burden and a lower Berry ratio than independent companies.
Regarding corporate taxation, it is proven that the increase in tax rates led to greater manipulation of intra-group transaction prices in order to reduce the tax burden. However, the tightening of the tax legislation, the transfer of responsibility for the control of intra-group transactions to the Ministry of Finance (now AADE), resulted in a reduction in manipulation, which was reflected in the gradual increase of the BR index.
The VAR regression models showed that there are short-term and long-term causal relationships between the variables analyzed, which provide significant indications that the values of the variables are directly or indirectly influenced by the practices of business managers in order to achieve the goal of the tax burden.
The empirical research of the present paper is unprecedented in Greece. The size of the sample in terms of number of companies, number of available ratios and time depth, allowed the analysis through a VECM model to examine the possible use of transfer pricing by affiliated companies to decrease their tax burden. The results provide the authorities a benchmark for future audits, since indicate that the manipulation is significant both in short, as well as in a long-term time frame. The use of a VECM model with two lags revealed that the manipulation is not limited within one financial year and the authorities should inspect data from a wider time range when conducting their audits.

Social, Political and Economic sciences

transfer pricing, manipulation of earnings, tax evasion, tax administration, tax audits, Greece, affiliated companies, independent companies, international taxation, MNCs, VECM model.

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https://pergamos.lib.uoa.gr/uoa/dl/object/2959426