* Tax authorities: They play a crucial role in ensuring that transfer prices are set at "arm's length," meaning they reflect what unrelated parties would have agreed upon in a comparable transaction. This prevents MNCs from manipulating prices to shift profits to low-tax jurisdictions and reduce their overall tax burden.
* Companies: Companies are responsible for establishing their transfer pricing policies and documenting the rationale behind their pricing decisions. They must comply with the arm's length principle and local tax regulations.
* Tax treaties: Bilateral tax treaties between countries often include provisions regarding transfer pricing, aiming to prevent double taxation and ensure fair allocation of taxing rights.
* International organizations: Organizations like the OECD (Organisation for Economic Co-operation and Development) develop guidelines and standards for transfer pricing, influencing national tax laws and promoting consistency across jurisdictions.
In short, transfer pricing involves a complex interplay between multinational companies, their tax jurisdictions, and international regulatory bodies.