Transfer pricing as a related-party transaction remains a significant concern due to its potential conflict with tax regulations. This study aims to examine the effects of board characteristics, income tax rate, and debt covenants on transfer pricing, with foreign ownership as a moderating variable, while controlling for company size and firm age. The novelty of this study lies in explicitly incorporating foreign ownership as an internal governance mechanism that moderates the interaction between governance, taxation, and financial pressure in shaping transfer pricing behavior. This area remains underexplored in prior empirical studies in Indonesia, thus contributing to the transfer pricing literature by emphasizing the role of foreign ownership as a governance mechanism influencing transfer pricing decisions. This study adopts a quantitative methodology by examining secondary data from 844 non-financial companies listed on the Indonesia Stock Exchange over 2020–2024 (4.220 unit observations). The analysis utilizes panel data regression and moderated regression analysis (MRA). The results indicate that income tax rate and debt covenants have a significant positive effect on transfer pricing, whereas board characteristics show no significant influence. Foreign ownership weakens the effect of debt covenants on transfer pricing but does not moderate other relationships. The findings offer practical insights for policymakers, tax authorities, and multinational firms in strengthening risk-based oversight and governance to manage transfer pricing risks.
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