Volume 5, Number 3, 2020, 33 – 48

Transfer Pricing, A New Challenge for Cambodia


Varabott Ho, MSc, MBA, CEFA.

Professor, CamEd Business School

Email: [email protected]


The concept of “Transfer pricing” emerged as early as 1917 (Collins, 2013)1, has evolved internationally since. It determines how the worldwide income of a multinational enterprise is divided among countries for income tax purposes when transactions occur within the firm. This paper examines economic, accounting, legal research, and tax practitioner literature on international transfer pricing. The theoretical literature reflects many different perspectives, but a recurring theme is that the current national and international tax systems keep evolving in a world where firms tend to create value by developing and choosing organizational structures which economize on transaction costs. The empirical literature documents the methodologies used by enterprises, focusing on Cambodia, and how international companies will need to operate in order to be compliant with the new domestic and regional tax framework.

The research on international transfer pricing is found in journals that reflect very different research traditions. Leading papers can be found in economics journals, accounting journals, law reviews, and tax practitioner journals.


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CamEd Center for Business Research