scholarly journals Transfer Pricing In Transnational Operations: A Case- And Literature-Based Analysis

2011 ◽  
Vol 2 (8) ◽  
Author(s):  
Virginia A. Taylor ◽  
E.J. (Roy) Knaus ◽  
William E. Matthews
Keyword(s):  
Marketing Strategy ◽  
Transfer Pricing ◽  
International Management ◽  
Management Team ◽  
Multinational Firm ◽  
Academic Environments ◽  
Organizational Perspective ◽  
Cost Allocations ◽  
The Difference ◽  
Competitive Marketing Strategy

This paper represents a combined case- and literature-based analysis of transnational pricing and highlights the difference in the issues and perspectives of the business and academic environments. Following an introduction to the issue (noting the growing importance of the transfer of goods from one organizational entity to another within a multinational firm), a short case - The Henderson Company - illustrates how a relatively simple announcement can lead to a lengthy and heated discussion that points out the differences in opinion both between the headquarters and the subsidiaries and between the various regional entities themselves. The analysis of the case reflecting the concerns and perspectives of the members of the international management team (in terms of involvement and partnership, legal and operational concerns, competitive marketing strategy, and evaluation, compensation, and motivational issues) is followed by a literature-based analysis that looks at the complexities of the situation in terms of management, economics, taxation, and finance research. The paper concludes with the recognition that the issue of transnational pricing is a complex one that needs to be addressed from both an organizational perspective and from an international viewpoint emphasizing the development of ways of more accurately reflecting cost allocations.

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.

Improving The Formation Of Competitive Marketing Strategy For Corporate Structures

2021 ◽  
Vol 3 (06) ◽  
pp. 60-66
Author(s):  
Akram Ziyaevich Amirkulov ◽  
Keyword(s):  
Corporate Governance ◽  
Marketing Strategy ◽  
Market Economy ◽  
Chemical Industry ◽  
Competitive Marketing Strategy

The article discusses the issues of improving the formation of a competitive marketing strategy in the corporate structures of the chemical industry in a market economy, consistent with the efficiency of corporate governance.

scholarly journals Gray Markets and Multinational Transfer Pricing

2011 ◽  
Vol 87 (2) ◽  
pp. 393-421 ◽  
Author(s):  
Romana L. Autrey ◽  
Francesco Bova
Keyword(s):  
Social Welfare ◽  
Marginal Cost ◽  
Transfer Pricing ◽  
Foreign Market ◽  
Multinational Firm ◽  
Foreign Subsidiary ◽  
Foreign Subsidiaries ◽  
Gray Market ◽  
Pricing Rules ◽  
Transfer Prices

ABSTRACT Gray markets arise when a manufacturer's products are sold outside of its authorized channels, for instance when goods designated by a multinational firm for sale in a foreign market are resold domestically. One method multinationals use to combat gray markets is to increase transfer prices to foreign subsidiaries in order to increase the gray market's cost base. We illustrate that, when a gray market competitor exists, the optimal transfer price to a foreign subsidiary exceeds marginal cost and is decreasing in the competitiveness of the domestic market. However, a multinational's discretion in setting transfer prices may be limited by mandatory arm's length transfer pricing rules. Provided gray markets exist, we characterize when mandating arm's length transfer pricing lowers domestic social welfare relative to unrestricted transfer pricing. We also demonstrate that gray markets can lead to higher domestic tax revenues, even when gray market firms do not pay taxes domestically.

scholarly journals KESEPAKATAN TERHADAP BRAND WONDERFUL INDONESIA: KAJIAN TERHADAP PELANCONG DAN PEGAWAI PEMERINTAH

2018 ◽  
Vol 2 (2) ◽  
pp. 71
Author(s):  
Diah Febrina
Keyword(s):  
Marketing Strategy ◽  
Theoretical Framework ◽  
Creative Economy ◽  
Test Results ◽  
Government Employees ◽  
Tourism Marketing ◽  
Five Elements ◽  
The Difference ◽  
The Republic ◽  
Difference Test

This study aims to review the agreement in the Visit Indonesia Year tourism marketing strategy through the Wonderful Indonesia brand. This study uses the theory of co-orientation as a theoretical framework. A total of 204 respondents consisting of 110 travelers and 94 government employees in the Ministry of Tourism and Creative Economy of the Republic of Indonesia were interviewed using a set of questionnaires. Based on the results of this study it was found that travelers and government employees did not have an agreement in perceiving Indonesia through the Wonderful Indonesia brand. However, the difference test results based on five elements in the Wonderful Indonesia branding show that travelers and government employees agree that the Indonesian people are friendly people.    

scholarly journals THEORETICAL AND METHODOLOGICAL ASPECTS OF FORMATION AND DEVELOPMENT OF SMM ENTERPRISE STRATEGY

2021 ◽  
Author(s):  
Andrii Holitsyn
Keyword(s):  
Marketing Strategy ◽  
Business Strategy ◽  
Rejection Rate ◽  
Viewing Time ◽  
Software Products ◽  
Content Strategy ◽  
Traditional Marketing ◽  
The Difference ◽  
Community Concept ◽  
Methodological Aspects

The article reveals the theoretical and methodological aspects of the formation and development of enterprise marketing strategy in social networks (SMMS), as the most popular and has some positive dynamics in its use by various companies in many markets. The essence of SMMS is outlined, the expediency of its use and scale for enterprises of different sizes are determined. The author determined that the SMM strategy is used as a part of the marketing strategy of the enterprise, which, in turn, should be organically consistent with the company’s business strategy. The taxonomy of SMMS classification is studied and examples of the use of such strategies for large brands are given. The difference between SMMS and traditional marketing strategy is given, SMMS’ goals are short-term and long-term, as well as their hierarchy. The author’s vision of the SMMS development algorithm is offered as well as the main obligatory components that such a strategy should contain. The stages of SMMS development are given, which include defining the community concept, forming goals and objectives, defining KPI system, analyzing competitors and their content strategy, as well as developing your own content strategy, choosing sites where the target audience is concentrated, drawing up a schedule using various software products such as MS Project, Ganttpro and performance evaluation and adjustment campaigns. It also identifies key developers in the company who can participate in its formation. The main indicators of efficiency, which can be used to draw conclusions about its success, including the number of subscribers, ER, ERR, generation of leads, etc are given. It is determined that content marketing within SMMS acts as a mandatory multi-channel marketing strategy, which includes three main components: actually content, design, usability and has its own KPI, such as viewing time, listening, rejection rate, likes, sharing, comments, clicks and conversions. Thus, it is concluded that SMMS is radically different from existing traditional marketing strategies, but is not properly formalized and may have a unique structure, and companies can have their own unique experience building SMMS depending on the company and the market.

The Effects of Joint Cost Allocation on Intra-Firm Trade: A Comparison of Insulating and Non-Insulating Approaches

2016 ◽  
Vol 29 (2) ◽  
pp. 1-10 ◽  
Author(s):  
Anil Arya ◽  
Jonathan C. Glover ◽  
Brian Mittendorf
Keyword(s):  
Private Information ◽  
Cost Allocation ◽  
Transfer Pricing ◽  
Trade Barriers ◽  
Cost Allocations ◽  
Mutual Monitoring ◽  
Fruitful Cooperation

ABSTRACT While it is generally believed that insulating cost allocations help managers focus their attention on their own actions and shield them from the actions of others, non-insulating schemes can have appeal by encouraging teamwork and/or mutual monitoring among divisions. In this paper, we demonstrate that non-insulating allocations can induce fruitful cooperation among parties even when teamwork and mutual monitoring are nonissues. In particular, we show that in the case of intra-firm trade governed by transfer pricing, non-insulating allocations can permit one division to internalize benefits of private information borne by another and thereby alleviate information-induced trade barriers. Unlike in the traditional case of fostering teamwork, however, the cooperative nature of non-insulating allocation introduced by information differences is distinctly more circumstance-specific. In line with this view, the paper also identifies conditions under which the use of non-insulating allocation shifts divisional incentives in a manner that only adds further tension to trade.

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