International Journal of Applied Business and International Management
Vol 10, No 1 (2025): April 2025

The Arm's Length Principle in Mitigating Tax Avoidance: A Systematic Literature Review

Ardika, I Kadek Agus (Unknown)
Ardianti, Putu Novia Hapsari (Unknown)
Nindia Putri, Cokorda Istri Agung Evita (Unknown)



Article Info

Publish Date
19 Apr 2025

Abstract

This study examines the effectiveness of Transfer Pricing Documentation (TP Doc) in supporting the Arm’s Length Principle (ALP) to reduce tax avoidance through related-party transactions (RPTs), especially involving tax haven jurisdictions. Using a Systematic Literature Review (SLR) approach, 15 relevant studies published between 2015 and 2024 were analyzed. The literature was selected based on keywords such as “Profit Shifting,” “Tax Haven,” “Related Party Transaction,” “Tax Avoidance,” and “Transfer Pricing.” The findings indicate that TP Doc contributes significantly to enhancing transparency and providing accurate information that enables tax authorities to evaluate whether intercompany transactions reflect fair market values. However, its implementation faces several challenges, including limited access to reliable data, inconsistencies in international standards, low compliance levels, and exploitable loopholes. Additionally, multinational enterprises (MNEs) frequently use RPTs to shift profits to low-tax jurisdictions, reducing their overall tax obligations. The study highlights the need to strengthen regulations, enhance tax authority enforcement, and promote international cooperation to ensure TP Doc effectively supports Indonesia’s tax reform and compliance efforts.

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Journal Info

Abbrev

IJABIM

Publisher

Subject

Humanities Decision Sciences, Operations Research & Management Economics, Econometrics & Finance Education Social Sciences

Description

The International Journal of Applied Business and International Management (IJABIM) is a peer-reviewed journal that provides a platform for scholars, professionals, and policymakers to share pioneering research in international business, management, and economics. Published quarterly, the journal ...