الفهرس 
قياس السعر المحايد بين الأطراف ذوي العلاقةيوجد فقط 14 صفحة متاحة للعرض العام
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المستخلص
Abstract
This study investigate statistically validity of using actual accounting data of income statement for 37 listed firms works through three main industrial sectors , these sectors are metal , foods and pharmaceutical industries from the period of 2005 – 2010 . we succeeded in designing an accounting model has the ability of measuring income tax due to transfer pricing adjustments. The model can perform these adjustments under Egyptian code No 91 ( 2005 ) using cost plus - method . the suggested accounting model contain four sub models , the first ( which is considered the main model ) interested in measuring gross operating profit ratio , the second related to measure gross profit range ratio , whereas the third interested in measuring the arm’s length price , finally the fourth measure the income tax due to transfer pricing adjustments . we investigated all results of the main (first ) model statically using correlation technique and regression analysis at α = 0.01 and α =0.05 significance level , results shoes that the first variable ( cost of good sold ) was the main variable , it explain more than 98 % of variance in operating gross profit ratio for all sectors , whereas the other three variables did not affect the dependant variable because the cost of goods sold variable includes in fact most impacts of the other control variables , result also shoes that forecasting gross operating profit ratio under non liner regression model is more significance than liner regression model for the three sectors .the researcher had been apply the four models to all selected sectors ( two cases for each sector ) , we find that some firms may evade tax using non arm’s length price , but in the other hand we find others did not .
Introduction:-
Egypt has historically relied on high tax rates to maintain its revenue base. At the same time, it has introduced tax incentives to compensate for the high tax rates and other deficiencies in the enabling environment for investment , so After Appling the code no 90 in the year of 2005 Egypt became a tax haven , because of reducing tax rate from 42 % to 20% , so we think that the big reduction in tax rat encourage most of big firms to designate a transfer pricing systems may has the ability to shift income from ( or to ) Egypt . although code No 91 introduce a number of accepted transfer pricing methodologies (TPMs) used to apply the arm’s length principle , However, there is a lack of conceptual mathematical approach to transfer pricing analysis. , so we think that Egyptian tax authority need a modern tool that has the ability to forecast firms behavior related to transfer pricing, we think that this tool must begin with forecasting gross operating profits ( which is the base for determine the arm’s length price ) to help tax examiner in performing adjustments for functions performed , according to research view the suggested tool ( or model ) must be conceptual as well as being able to be applied statically or dynamically.
Problem statement:-
After Appling the code no 90 in the year of 2005 Egypt become a tax haven , because of big reductions in tax rate from 42 % to 20% , so some firms that has some related parties outside ( and inside ) the country uses some mechanism to reduce the effected tax rate , using income shifting technique , the main mechanism that related parties uses to shift profit to some affiliates may be through purchase & selling properties , using financial instruments especially swaps contracts , shift expenditures to non exempt affiliates whereas shift revenue to exempt affiliates , so the main problem is represented in the following points :
• The Egyptian tax authority could not know weather related parties as whole apply arm,s length price or not
• tax authority has not the tools wich help taxman in forecasting weather firms shift income or not .
• Tax authority apply some manually tools that has no efficiency when measure arms’ length price
• Finally it couldn’t uses last financial data in forecasting gross operating profit which is considered the raw data in measuring arm’s length price
Study objectives
The study tries to answer the following questions
• Distance of the validity of the tools that tax authority apply nowadays in measuring the arm’s length price
• The validity of measuring tax income during arm’s length price statically through an accounting model, in the same time this model depends on the secondary data received by tax authority which listed in the annual tax form for each firm .
Study importance
• Determine weather related parties involved in tax evasion or not
• Determining through empirical evidence weather firms prices performed in a fair base or not.
• Enhancing the tax examiner role , by introducing a modern conceptual tool ( or model ) as well as being able to be applied statically or dynamically.
Study limits:-
• This model can apply only on metal , foods and pharmaceutical industries .so any firm outside this area like distributers or those that work in services activities , are outside the scope of this study
• This model uses through cost – plus method only
• That study concern only with firms that has a related parties .
• The application of the study will be on tax income only according to code no 91 , so sales tax & other types of taxes are out of study scope
Study hypotheses :-
On the light of research problem and its objectives this study tries to verify the validity of the following hypotheses :-
First :-
there is no relationship between the cost of goods sold ratio and gross operating profit ratio for the three industrial sectors.
Second :-
there is no relationship between leverage , capital insinsity , liquidity ratios , with gross operating profit ratio for the three industrial sectors
Third :-
there is no a high degree of significance for the liner model when forecasting gross operating profit comparing with the nonlinear model .
Research methodological
In order to achieve research objectives’ and testing its hypotheses – stated above – the researcher will use statistical & empirical analysis . a group of available methods are used for data analysis , we used correlation and regression analysis ( liner & non liner ) in order to obtain a high R2 and low standard error , statistical methods used as follow :-
• Correlations technique at 0.01 & 0.05 significant level .
• Stepwise regression
• R .square and adjusted R2
• Global test ( F.Test )
• T.Test
• Durbin Watson Test
So we think that the following equations stated below are suitable for achiving the purpose of the study :-
The first equation used in this study is as follow :
y I + εi
where :-
y i = the dependent variable for company from 1 to J .
= the intercept of the equation
Xj = the observation on the independent variabl
= the coefficient of the independent variable to be estimated from the data . εi = the unexplained variation in gross operating profit that is attributed to some other factors.
yi = α+ β1(X1i) +β2(X2i)+ β3 (X3i)+ β4 (X4i) + εi for 1 to J comparables.
where :-
g i = gross operating profit ratio ( GROSS) for company i
X1i = Leverage ratio (LEV) for company i
X2i = Capital insinsity ratio (CAP) for company i
X3i = Liquidity Ratio (LIQ) for company i
X4i = Cost of good sold (COGS) for company i
= the coefficient of the independent variable to be estimated from the data
1 to J = sample size
The model used in this study is :
This model lead to the following equation :-
where
g i = gross operating profit ratio
f (xi)= independent variable
ε = standard error of estimation
The third model used in this study is as follow :
The third equation divided into two equation as follow :
Mini Gross operating profit Range = gi – t (εi)……….3(A)
Max Gross operating profit Range = gi + t (εi)…….…3(B)
Fourth model ( measure arm’s length price ) as follow
Fifth model ( measure arm’s length price ) as follow
Finally, to archive study objectives the researcher would dived the study into the following parts :
Part one :-
Part one dealt with the framework of the study, which contain the introduction, problem statement, study objectives, hypotheses, research limits, and the importance of the study
Part one :-
This part contain a brief review of the last literature, which help researcher to understand the problem and the suggested aspects’ to deal with it .
Part two:
This part dealt with measuring the arm’s length price in code no 91 and accounting standards , which gave the researcher the ability to discover the main problems in this code .
Part three :-
This part dealt with the main factors affected profitability of industrial firms , this part help the researcher to identify the variables of the first model which is consider the raw step to measure tax income due to transfer pricing
Part four :-
This part dealt with research method , and data collection which depended on the actual financial data introduced by firms to the tax authorities , the sample contain 38 listed firms work in foods , metal , and pharmaceutical industries sectors . selection of these firms had been done according to some standards as follow :-
• Cover most of industrial activities.
• These firms audited through big auditing firms.
• Following the same cost accounting policies
This part also dealt with testing hypotheses, after collecting data for each sector , we used one of the most efficient statistical program , SPSS . Version 16 , we used correlation technique , R2 , enter regression , T . Test & F . test and finally Durbin Watson test.
Also This part dealt with an empirical application of the four suggested models to the three selected sectors , two cases (company ) for each sector , we find that some firms evade tax using non arm’s length price , but in the other hand we find others did not.