The Impact of Transfer Pricing Regulations on the Location Decisions of MNEs

2015 ◽  
pp. 81-106 ◽  
Author(s):  
Jumpei Ito ◽  
Yoshimasa Komoriya
Keyword(s):  
Transfer Pricing ◽  
Location Decisions ◽  
The Impact

TRANSFER FİYATLAMA UYGULAMASININ İŞLETME PERFORMANSINA ETKİSİ VE VERGİSEL AÇIDAN DEĞERLENDİRİLMESİ

2014 ◽  
Vol 1 (2) ◽  
pp. 187
Author(s):  
Serdar KUZU
Keyword(s):  
Business Performance ◽  
Transfer Pricing ◽  
Tax Law ◽  
Economic Activities ◽  
Tax System ◽  
Goods And Services ◽  
Tax Legislation ◽  
International Transactions ◽  
The Cost ◽  
The Impact

The size of international trade continues to extend rapidly from day to day as a result of the globalization process. This situation causes an increase in the economic activities of businesses in the trading area. One of the main objectives of the cost system applied in businesses is to be able to monitor the competitors and the changes that can be occured as a result of the developments in the sector. Thus, making cost accounting that is proper according to IAS / IFRS and tax legislation has become one of the strategic targets of the companies in most countries. In this respect, businesses should form their cost and pricing systems according to new regulations. Transfer pricing practice is usefull in setting the most proper price for goods that are subject to the transaction, in evaluating the performance of the responsibility centers of business, and in determining if the inter-departmental pricing system is consistent with targets of the business. The taxing powers of different countries and also the taxing powers of different institutions in a country did not overlap. Because of this reason, bringing new regulations to the tax system has become essential. The transfer pricing practice that has been incorporated into the Turkish Tax System is one of the these regulations. The transfer pricing practice which includes national and international transactions has been included in the Corporate Tax Law and Income Tax Law. The aim of this study is to analyse the impact of goods and services transfer that will occur between departments of businesses on the responsibility center and business performance, and also the impact of transfer pricing practice on the business performance on the basis of tax-related matters. As a result of the study, it can be said that transfer pricing practice has an impact on business performance in terms of both price and tax-related matters.

scholarly journals Substitution across profit shifting methods and the impact on thin capitalization rules

2021 ◽  
Author(s):  
Gideon Goerdt ◽  
Wolfgang Eggert
Keyword(s):  
Multinational Firms ◽  
Transfer Pricing ◽  
Multinational Firm ◽  
Profit Shifting ◽  
Goods And Services ◽  
Internal Goods ◽  
Transfer Prices ◽  
Debt Shifting ◽  
The Impact ◽  
Thin Capitalization

AbstractThin capitalization rules limit firms’ ability to deduct internal interest payments from taxable income, thereby restricting debt shifting activities of multinational firms. Since multinational firms can limit their tax liability in several ways, regulation of debt shifting may have an impact on other profit shifting methods. We therefore provide a model in which a multinational firm can shift profits out of a host country by issuing internal debt from an entity located in a tax haven and by manipulating transfer prices on internal goods and services. The focus of this paper is the analysis of regulatory incentives, $$(i)$$ ( i ) if a multinational firm treats debt shifting and transfer pricing as substitutes or $$(ii)$$ ( i i ) if the methods are not directly connected. The results provide a new aspect for why hybrid thin capitalization rules are used. Our discussion in this paper explains why hybrid rules can result in improvements in welfare if multinational firms treat methods of profit shifting as substitutes.

scholarly journals Corporate Income Shifting in an Era of Tax Multilateralism: The Impact of Exchange-of-Information Agreements

2021 ◽  
Vol 69 (2) ◽  
pp. 357-389
Author(s):  
Devan Mescall ◽  
Paul Nielsen
Keyword(s):  
Multinational Corporations ◽  
Multinational Enterprises ◽  
Transfer Pricing ◽  
Empirical Studies ◽  
Annual Reports ◽  
Income Shifting ◽  
Exchange Of Information ◽  
Pricing Rules ◽  
Using Data ◽  
The Impact

Using data from the annual reports of over 100,000 subsidiaries of multinational enterprises (MNEs) from 55 countries between 2003 and 2012, the authors of this article investigate the impact of exchange-of-information agreements ("EOI agreements") on tax-motivated income shifting. Transparency created by the signing of EOI agreements is expected to reduce the tax-motivated shifting of income by multinational corporations. Whether such agreements affect the income-shifting behaviour of multinational corporations is an unanswered question. The authors find evidence that, on average, EOI agreements do have an impact on tax-motivated income shifting. Additionally, they find that more advanced, modern EOI agreements are associated with a larger decrease in tax-motivated income shifting compared to the impact of early EOI agreements. This evidence challenges the prevalent assumption in empirical studies that EOI agreements are homogeneous. Supplemental analyses suggest that factors that affect the information asymmetry between MNEs and tax authorities, such as corporations with high levels of intangibles and tax authorities with strong transfer-pricing rules and enforcement, can diminish or enhance the effectiveness of EOI agreements in moderating tax-motivated income shifting. The evidence provided by this study shows that consideration of the tax authorities' information environment and the substance of an EOI agreement is essential when assessing the impact of such an agreement on the tax behaviour of sophisticated taxpayers such as multinational corporations.

scholarly journals Remedies to Illicit Financial Flows from Transfer Pricing of Services and Hosting Intellectual Property in Kenya

2017 ◽  
Vol 3 (1) ◽  
pp. 113-130
Author(s):  
Charles Gordema
Keyword(s):  
Transfer Pricing ◽  
Primary Concern ◽  
Financial Flows ◽  
Taxable Income ◽  
Global Corporation ◽  
Intellectual Assets ◽  
Global Corporations ◽  
Illicit Financial Flows ◽  
The Impact ◽  
Pricing Of Services

Numerous reports in the last decade have focused on the challenges to African economies that emanate from the illicit transfers of funds and other valuable assets within some global corporations. A primary concern is the impact of these transfers on the taxable income of African subsidiaries. Two broad categories of intra-group transfers are of particular interest, partly because of the complexities they raise. One comprises transfers in payment of services exchanged among associated enterprises, while the other pertains to transfers by subsidiaries in payment of the value of intellectual assets attributed to the corporate centre of the global corporation. This article highlights the challenges raised by these transfers through case studies. It examines possible mechanisms to mitigate the challenges, drawing attention to current and impending developments. It concludes that there are good prospects for curbing illicit transfers linked to the examined types of transactions.

The Impact of Tax and Transfer Pricing on a Multinational Firm's Strategic Decision of Selling to a Rival

2019 ◽  
Vol 28 (9) ◽  
pp. 2279-2290 ◽  
Author(s):  
Vernon N. Hsu ◽  
Wenqiang Xiao ◽  
Jiayan Xu
Keyword(s):  
Transfer Pricing ◽  
Strategic Decision ◽  
The Impact

scholarly journals Experimental Evidence on Transfer Pricing

2016 ◽  
Vol 50 (1) ◽  
pp. 27-48 ◽  
Author(s):  
Quoc H. Tran ◽  
Rachel T. A. Croson ◽  
Barry J. Seldon
Keyword(s):  
Transfer Pricing ◽  
Tax Rates ◽  
Optimal Transfer ◽  
Policy Interventions ◽  
Economics Experiments ◽  
Theoretical Predictions ◽  
Transfer Prices ◽  
Partial Ownership ◽  
Tariff Rates ◽  
The Impact

Abstract We use incentivized economics experiments to test both the point predictions and comparative static predictions of optimal transfer pricing models, comparing behavior under varying conditions, including wholly versus partially-owned subsidiaries and different tariff and tax rates. As predicted, we find that transfer prices are responsive to relative tax and tariff rates as well as ownership proportions. Additionally, we examine convergence and learning in this setting. While individuals do not choose optimal transfer prices, their choices converge to optimal levels with experience. This paper thus makes two important contributions. First, by comparing behavior with theoretical predictions it provides evidence of whether (and when) individuals set transfer prices optimally. Second, by comparing behavior under conditions of full and partial ownership it provides evidence on the impact of policy interventions (like regulating ownership proportions by MNEs) on tax revenues.

scholarly journals The Impact of Tax, Exchange Rate, Tunneling Incentive and Firm Size on Transfer Pricing (Empirical Study of Manufacturing Companies Listed on the Indonesian Stock Exchange for Years2014-2018)

2019 ◽  
Vol 1 (2) ◽  
pp. 149-166
Author(s):  
Felicia Vanessa Wijaya ◽  
Luky Patricia Widianingsih
Keyword(s):  
Exchange Rate ◽  
Firm Size ◽  
Stock Exchange ◽  
Transfer Pricing ◽  
Secondary Data ◽  
Annual Reports ◽  
Manufacturing Companies ◽  
Factors Affecting ◽  
Analysis Technique ◽  
The Impact

Abstract: In the era of globalization, companies are developing into multinational companies that establish branches or subsidiaries in various countries. This globalization has given an impact to increase international transaction. These transactions could lead to transactions with related parties that shows an indication of transfer pricing. Along with the development of globalization, factors affecting transfer pricing are not only derived from taxes, but also from other factors. The purpose of this research is to examine the effect of tax, exchange rate, tunneling incentive, and firm size on transfer pricing. This research used secondary data in the form of annual reports published on the Indonesia Stock Exchange. Population of this research was manufacturing companies for years 2014-2018 and by purposive sampling method, a sample of 19 manufacturing companies was obtained. Analysis technique used on this research was a multiple linear regression using SPSS 23 application. The result shows that tax, tunneling incentive, firm size have significant effect on transfer pricing, while exchange rate does not take any effect on transfer pricing. Adjusted R2 determination coefficient of 32,8% shows transfer pricing is affected by tax, exchange rate, tunneling incentive, and firm size, while remaining 67,2% is affected by other variables outside research model. Keywords: Transfer Pricing; Tax; Exchange Rate; Tunneling Incentive; Firm Size.

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