Understanding Global Value Chains: How Businesses Operate in Interconnected Networks Across Borders and Why It Matters for Tax and Transfer Pricing

July 18, 20230



In today’s globalized economy, businesses are increasingly operating in interconnected networks across borders, leading to the emergence of Global Value Chains. Global Value Chains represent the entire range of activities involved in the production of goods and services, from conception to final consumption. Understanding how businesses operate within Global Value Chains is crucial for policymakers, tax authorities, and companies themselves. This article explores the concept of Global Value Chains, their significance in today’s economy, and the implications they have for tax and transfer pricing. 


Understanding Global Value Chains 

Global value chains refer to the complex networks of companies, suppliers, and customers that participate in the production and distribution of goods and services worldwide. These chains involve the coordination of various stages of production across different countries, where each participant specializes in a specific task or process. For instance, a company might design a product in one country, source raw materials from another, manufacture it in a third country, and distribute it globally. This intricate division of labor allows businesses to leverage efficiencies, cost advantages, and access to specialized resources. 


The Significance of Global Value Chains 


Economic Growth and Competitiveness: Global Value Chains play a vital role in driving economic growth and enhancing a country’s competitiveness. By participating in Global Value Chains, firms can access larger markets, benefit from economies of scale, and tap into specialized skills and technologies. Additionally, Global Value Chains facilitate knowledge spillovers and technology transfer between countries, fostering innovation and productivity improvements. 


Employment and Skills Development  


Global Value Chains contribute significantly to employment generation, particularly in developing countries. These chains create job opportunities at various stages of production, from assembly line workers to skilled professionals involved in research and development. Moreover, Global Value Chains participation often leads to skill development and knowledge acquisition, enabling individuals to acquire new capabilities and improve their livelihoods. 


Trade and Investment 


Global Value Chains have become a driving force behind global trade and investment flows. Companies establish international linkages within Global Value Chains to optimize their supply chains, access new markets, and diversify risks. Such interconnections encourage foreign direct investment (FDI) and facilitate the flow of capital, technology, and expertise across borders. 


Tax and Transfer Pricing Implications 


While Global Value Chains offer numerous benefits, they also pose challenges for tax authorities in determining the appropriate allocation of profits and tax liabilities. Here are key considerations related to tax and transfer pricing in the context of Global Value Chains: 

Profit Shifting and Base Erosion 


Global Value Chains can create opportunities for MNEs to manipulate transfer prices and shift profits to low-tax jurisdictions, thereby reducing their overall tax burden. This practice, known as profit shifting, can erode the tax base of countries where value creation activities occur. Policymakers aim to address these issues by implementing measures such as the OECD’s Base Erosion and Profit Shifting (BEPS) initiative to enhance transparency and prevent tax avoidance. 


Double Taxation and Tax Treaties 


Global Value Chains involving multiple jurisdictions can lead to potential double taxation, where the same income is taxed in multiple countries. To mitigate this, countries enter into tax treaties that provide mechanisms for the elimination or reduction of double taxation. These treaties establish rules for allocating taxing rights and resolving disputes between countries. 


Country-by-Country Reporting (CbCR) 


To enhance tax transparency and combat profit shifting, many jurisdictions require MNEs to file country-by-country reports. These reports provide tax authorities with detailed information on the global allocation of income, taxes paid, and economic activities of MNEs. CbCR enables tax authorities to assess transfer pricing risks and take appropriate actions to protect their tax base. 




Global value chains have transformed the way businesses operate in today’s interconnected world. They drive economic growth, foster employment, and facilitate trade and investment. However, the complexity of Global Value Chains presents challenges in the realm of tax and transfer pricing. Policymakers and tax authorities must keep pace with the evolving nature of global value chains to ensure fair taxation and prevent profit shifting. Effective coordination, international cooperation, and the implementation of robust tax policies are vital to strike a balance between encouraging cross-border business operations and safeguarding tax revenues. 

Author: Amir Gholizadeh, Junior Associate, TPA Global



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