Suchergebnisse

AbstractAn analysis of the literature of transfer pricing is presented. It is shown that, under assumptions that the firm and its divisions have full deterministic knowledge of their costs and demands, some form of average cost is the appropriate transfer price. What happens when a firm adopts an objective other than profit maximization is further examined.

"Tax-motivated transfer pricing has attracted world attention owing to the existence of low-tax
jurisdictions and the volume of the activities of multinational corporations (MNCs). MNCs
have many instruments for shifting profits through transfer pricing, and tax havens provide ample
opportunity for this. Tax havens pose the threat of capital flight and income shifting from
high-tax countries. At present, there are two ways of tackling this problem: by applying the
arm's length principle to determine the tax payable by MNCs in a particular jurisdiction or by
using a formula to allocate tax payable by MNCs between countries. Based on various studies
conducted so far, this paper summarizes the advantages and disadvantages of these methods in
solving the problem of profit-shifting by MNCs. The predicament is truly global in nature, and
no single country or group of countries can hope to resolve it. It is high time a global institution
was set up to calculate MNCs' worldwide income and to provide tax authorities with timely
information." [author's abstract]

We demonstrate that the choice of the transfer price and its effect on intra-firm trade and investment depends on the probability of detection and thus on the measure, on which tax authorities base their audit. A policy implication of the paper is that it should be preferable to condition audits on the amount of income shifted rather than on the distortion of the transfer price proper. Another policy finding is that improving the quality of tax law might be superior to higher detection effort. The former reduces profit shifting and concealment effort, whereas the latter leads to more wasteful use of resources on concealment and has an ambiguous effect on profits shifted.

In this paper we set up a symmetric two-country model with trade costs and international ownership to study the transfer pricing decisions by two multinationals operating in markets with Cournot competition. We let governments choose both the corporate profit tax rate and the level of enforcement of the "arm's length" principle and we examine how enforcement policies affect the tax competition game. Furthermore, we analyze in what direction economic integration, in terms of a reduction in trade costs and/or a larger international ownership of multinationals, influences the symmetric equilibrium level of the two policy instruments. We show that increased economic integration may lead to higher equilibrium tax rates, and that, as governments increase the level of enforcement, equilibrium tax rates increase as well. Moreover, we find that, when the two MNEs are not fully owned by domestic residents, trade liberalization decreases the equilibrium enforcement policy, while increased international ownership increases the level of enforcement.

In this paper we set up a symmetric two-country model with trade costs and international ownership to study the transfer pricing decisions by two multinationals operating in markets with Cournot competition. We let governments choose both the corporate profit tax rate and the level of enforcement of the "arm's length" principle and we examine how enforcement policies affect the tax competition game. Furthermore, we analyze in what direction economic integration, in terms of a reduction in trade costs and/or a larger international ownership of multinationals, influences the symmetric equilibrium level of the two policy instruments. We show that increased economic integration may lead to higher equilibrium tax rates, and that, as governments increase the level of enforcement, equilibrium tax rates increase as well. Moreover, we find that, when the two MNEs are not fully owned by domestic residents, trade liberalization decreases the equilibrium enforcement policy, while increased international ownership increases the level of enforcement.