scholarly journals Do Government Regulations Prevent Transfer Pricing Manipulations?

2011 ◽  
Vol 4 (10) ◽  
Author(s):  
Canri Chan
Keyword(s):  
Multinational Corporations ◽  
Transfer Pricing ◽  
Cash Flows ◽  
Transfer Price ◽  
Tax Rates ◽  
Performance Measurements ◽  
Government Regulations ◽  
Transfer Prices ◽  
Profit Performance ◽  
Efficient Allocations

This study investigated the effects of government regulations and incentives on the setting of transfer prices. I found significant main effects of both variables on transfer price choices. Transfer pricing is important, particularly for Multinational Corporations (MNCs), because of increased trends toward globalization of business activities and, simultaneously, decentralization. These trends have led to increased pressures for sound internal pricing systems, specifically transfer pricing, in order for organizations to ensure optimal and efficient allocations of organization resources and to provide profit performance measurements (Tang 1992). It has generally been recognized in the literature that in order to maximize after tax cash flows, MNCs shift profits from high to low tax jurisdictions. Governments in some countries, particularly those with high tax rates, are greatly concerned as to whether or not companies attempt to avoid tax liabilities via transfer pricing manipulation, specifically in terms of trying to shift profits to lower tax jurisdictions, and have enacted laws to limit transfer price choice.

scholarly journals Transfer Pricing: Impact of Taxes and Tariffs in India

2012 ◽  
Vol 37 (4) ◽  
pp. 29-46
Author(s):  
Pradeep Gupta
Keyword(s):  
Multinational Corporations ◽  
Home Country ◽  
Transfer Pricing ◽  
Transfer Price ◽  
Corporate Taxes ◽  
Tax Rates ◽  
Corporate Tax ◽  
Policy Makers ◽  
Corporate Tax Rates ◽  
Transfer Prices

Transfer pricing in an economy is very significant to corporate policy makers, economic policy makers, tax authorities, and regulatory authorities. Transfer pricing manipulation (fixing transfer prices on non-market basis as against arm's length standard) reduces the total quantum of organization's tax liability by shifting accounting profits from high tax to low tax jurisdictions. It changes the relative tax burden of the multinational firms in different countries of their operations and reduces worldwide tax payments of the firm. This paper explores the influence of corporate taxes and product tariffs on reported transfer pricing of Multinational Corporations (MNCs) in India by using the Swenson (2000) model. This study of custom values of import originating from China, France, Germany, Italy, Japan, Singapore, Switzerland, UK, and USA into India reveals that transfer pricing incentives generated by corporate taxes and tariffs provide opportunity for MNCs to manipulate transfer price to maximize profits across world-wide locations of operations and reduce tax liability. The main findings of this paper are: The estimates computed by grouping together products of all industries being imported into India from sample countries reveal that TPI coefficients are positive and significant. Overall, positive and significant coefficients of TPI predict that one per cent reduction in corporate tax rates in the home country of the MNC would cause multinational corporations with affiliated transactions to increase reported transfer prices in the range of 0.248 per cent to 0.389 per cent. The Generalized Least Square estimates for individual industries display that out of nine industries in the sample, three industries (38, 73, and 84) have a positive and significant co-movement with transfer pricing incentives. In four industries (56, 83, 85, and 90), coefficient of Transfer Pricing Incentive (TPI) is negative but significant. In case of two industries (39 and 82), TPI coefficient is negative but not significant. Positive and significant coefficients of TPI predict that one per cent reduction in corporate tax rates in the home country would cause multinational corporations with affiliated transactions to increase reported transfer prices by 1.20 per cent in ‘Miscellaneous Chemical Products’ Industry (Industry 38), 0.175 per cent in the ‘Articles of Iron or Steel’ Industry (Industry 73) and 0.908 per cent in �Nuclear Reactors, Boilers, Machinery and Mechanical Appliances; Parts thereof' Industry (Industry 84). In industries where coefficient of TPI is negative and significant, MNCs would like to shift the taxable income of their affilates to the host country by decreasing their reported transfer price. The government's approach should be to reduce corporate tax and tariff rates to bring them at a level comparable with countries across the world which will reduce incentives for the MNCs for shifting of income out of India and increase the tax base for tax authorities. This will also result in an increase in the tax revenue of the country.

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 TAX MORALITY: EXAMINING THE BEPS DEBATE, WORK OF THE OECD AND ITS IMPACT ON AFRICA

2017 ◽  
Author(s):  
Daniel Godson Olika
Keyword(s):  
Multinational Corporations ◽  
Transfer Pricing ◽  
Tax Rates ◽  
Profit Shifting ◽  
The Public ◽  
Pricing Rules ◽  
Planning Strategies ◽  
International Tax ◽  
Harsh Criticism ◽  
The Impact

International tax issues have never been at the forefront of international politics as they are today. This is due in large part to the realization that the current international tax system in existence allows multinational corporations to plan their taxes in such a way that they will be able to pay little or no taxes at all. They are able to do this through certain loopholes and gaps that currently exist in the system. These loopholes and gaps are seen as creating opportunities for taxpayers who are involved in cross-border activities to aggressively structure their activities to mitigate potential tax exposure or achieve no tax liabilities. They do this by exploiting; the hybrid-mismatch arrangements, shortcomings of the transfer pricing rules in jurisdictions where they operate and shifting profits from countries where their profits are made to countries with low tax rates. Consequently, some multinationals pay as little as five percent in corporate taxes, even as smaller domestic businesses pay up to 30 percent. The result of this activity is what is known as; base erosion and profit-shifting (BEPS) and it has the potential to deprive all countries of significant tax revenues. This rave debate and harsh criticism from the public influenced the intervention of the Organisation for Economic Co-operation and Development (OECD) to start its now famous BEPS Project. The OECD BEPS Project aims to provide governments or tax administrators with clear international solutions for fighting aggressive corporate tax planning strategies that artificially shift profits to locations where they are subjected to more favourable tax treatment. This paper shall address the various strands of the BEPS debate, the OECD BEPS project, the impact of the project in Africa and Nigeria. The next section shall address the various strands of the debate.

International Transfer Pricing and Tax Avoidance: Evidence from Linked Trade-Tax Statistics in the United Kingdom

2020 ◽  
Vol 102 (4) ◽  
pp. 766-778 ◽  
Author(s):  
Li Liu ◽  
Tim Schmidt-Eisenlohr ◽  
Dongxian Guo
Keyword(s):  
United Kingdom ◽  
Multinational Firms ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Tax Rates ◽  
Corporate Tax ◽  
The United Kingdom ◽  
Tax Returns ◽  
Medium Level ◽  
Transfer Prices

This paper employs unique data on export transactions and corporate tax returns of UK multinational firms and finds that firms manipulate their transfer prices to shift profits to lower-taxed destinations. It shows that the 2009 tax reform in the United Kingdom, which changed the taxation of corporate profits from a worldwide to a territorial system, led to a substantial increase in transfer mispricing. It also provides evidence for a trade creation effect of transfer mispricing and estimates substantial transfer mispricing in non-tax-haven countries with low- to medium-level corporate tax rates, and in R&D intensive firms.

Transfer Pricing System Based on the Method of Cash Flows Redistribution

2019 ◽  
Vol 8 (3) ◽  
pp. 67-74
Author(s):  
С. Ребров ◽  
S. Rebrov
Keyword(s):  
Transfer Pricing ◽  
Market Price ◽  
Cash Flows ◽  
Transfer Price ◽  
Negative Consequences ◽  
Average Value ◽  
System A ◽  
Pricing System ◽  
Research Analysis

The article describes the system of transfer pricing based on the method of cash flows redistribution, developed by the author. The article describes such concepts as transfer price, transfer pricing, transfer pricing system. Methodological tools of research: analysis, synthesis, system approach. The author used the method of cash flows redistribution, the description of which is given in this article. The transfer pricing system developed by the author is based on the determination of the transfer price interval on the basis of the transfer pricing methods allowed by tax law, as well as the average value of this interval. This average value can be considered as the average market price, which is determined by the specifics of transfer pricing methods. If there is a deviation from the average market price, there is a redistribution of funds between the subjects of the transaction. For the control of transfer price introduced the coefficient of cash flows redistribution. To manage the transfer pricing system, a matrix of cash flow redistribution coefficients was introduced, as well as the account "redistributed funds". The positive and negative consequences of the introduction of this system of transfer pricing are considered.

scholarly journals Transfer Pricing by Multinational Firms: New Evidence from Foreign Firm Ownerships

2016 ◽  
Vol 8 (3) ◽  
pp. 170-202 ◽  
Author(s):  
Anca D. Cristea ◽  
Daniel X. Nguyen
Keyword(s):  
Multinational Corporations ◽  
Multinational Firms ◽  
Transfer Pricing ◽  
Tax Rates ◽  
Profit Shifting ◽  
Firm Level ◽  
For Profit ◽  
Tax Returns ◽  
Triple Difference ◽  
Downward Bias

Using a firm-level dataset of Danish exports between 1999–2006, we find robust evidence for profit shifting by multinational corporations. Our triple difference estimations exploit the response of export unit values to acquisitions of foreign affiliates and to changes in statutory corporate tax rates. This identification strategy corrects for a downward bias resulting from firms adjusting arm's length prices to obscure transfer price manipulations. We find that Danish multinationals reduce the unit values of their exports to low tax countries between 5.7 to 9.1 percent. This difference corresponds to a tax revenue loss of 3.24 percent of Danish multinationals' tax returns. (JEL D21, D22, F14, F23, H25, H32)

scholarly journals IPTEKS PENGHITUNGAN HARGA TRANSFER DAN HARGA JUAL PADA RUMAH MAKAN KHOPINOS

2019 ◽  
Vol 3 (1) ◽  
Author(s):  
Novi Swandari Budiarso ◽  
Winston Pontoh
Keyword(s):  
Transfer Pricing ◽  
Transfer Price ◽  
Selling Price ◽  
Operating Profit ◽  
Transfer Prices ◽  
Medium Enterprise ◽  
The Right ◽  
Medium Businesses ◽  
The Cost

Determination of transfer prices and selling prices is not only a matter of large companies. This problem can occur in a type of Small and medium enterprise. But sometimes managers from small and medium businesses do not realize that in their business there is a transfer price transaction that can affect the selling price of the product to external consumers and subsequently affect operating profit. In order to overcome this problem, you can use the transfer pricing method and selling price so that you get the right transfer price and selling price for a business. The results of the transfer price calculation using the cost method and the selling price using the full cost method, the results of the transfer of semi-finished products from the preparation business unit are Rp. 4,900 / unit, while the selling price of the settlement division to external consumers is Rp. 11,020 / unit .Keywords : transfer price, selling price, cost based transfer price, market based transfer price, negotiated transfer price.

scholarly journals IPTEKS PENGHITUNGAN HARGA TRANSFER DAN HARGA JUAL PADA RUMAH MAKAN KHOPINOS

2019 ◽  
Vol 3 (01) ◽  
Author(s):  
Novi Swandari Budiarso ◽  
Winston Pontoh
Keyword(s):  
Transfer Pricing ◽  
Transfer Price ◽  
Selling Price ◽  
Operating Profit ◽  
Transfer Prices ◽  
Medium Enterprise ◽  
The Right ◽  
Medium Businesses ◽  
The Cost

Determination of transfer prices and selling prices is not only a matter of large companies. This problem can occur in a type of Small and medium enterprise. But sometimes managers from small and medium businesses do not realize that in their business there is a transfer price transaction that can affect the selling price of the product to external consumers and subsequently affect operating profit. In order to overcome this problem, you can use the transfer pricing method and selling price so that you get the right transfer price and selling price for a business. The results of the transfer price calculation using the cost method and the selling price using the full cost method, the results of the transfer of semi-finished products from the preparation business unit are Rp. 4,900 / unit, while the selling price of the settlement division to external consumers is Rp. 11,020 / unit .Keywords : transfer price, selling price, cost based transfer price, market based transfer price, negotiated transfer price.

Preservation of Incentives Inside the Firm: A Case Study of a Quasi-Market for Cost-Based Transfer Pricing

2019 ◽  
Vol 32 (2) ◽  
pp. 137-157
Author(s):  
Ivar Friis
Keyword(s):  
Organizational Design ◽  
Transfer Pricing ◽  
Transfer Price ◽  
Variable Cost ◽  
Control Mechanisms ◽  
Transfer Prices

ABSTRACT According to organizational economists, the implementation of market-like control mechanisms, such as transfer prices, can never completely replicate the market since “the use of high-powered incentives in firms is inherently subject to corruption” (Williamson 1985, 140). This paper illustrates that this is not necessarily always so. By means of a case study, this paper illustrates that many problems that extant research claims are related to cost-based transfer prices were mitigated through an organizational design that created a quasi-market inside the firm. The paper contributes to extant research in several ways. First, it illustrates that strong incentives are somewhat preserved through an organizational design that fosters competition between product divisions. Second, the paper shows how the specific problems related to a standard variable cost transfer price were mitigated. Finally, the paper highlights the limits of the quasi-market and describes a number of problems that required central intervention.

Dynamic transfer pricing under conditions of uncertainty – the use of real options

2019 ◽  
Vol 15 (4) ◽  
pp. 535-556 ◽  
Author(s):  
Jan M. Smolarski ◽  
Neil Wilner ◽  
Jose G. Vega
Keyword(s):  
Real Options ◽  
Transfer Pricing ◽  
Business Environment ◽  
Transfer Price ◽  
Operating Conditions ◽  
Options Pricing ◽  
Content Type ◽  
Pricing Mechanism ◽  
Managerial Flexibility ◽  
Transfer Prices

Purpose This paper aims to examine the applicability of real options methodology with respect to developing internal transfer pricing mechanisms. A pervasive theme in existing models is their inability to handle the dynamic and volatile nature of today’s business environment, as well as their lack of objective managerial flexibility. The authors address these and other issues and develop a transfer pricing mechanism based on Black–Scholes and the binomial options pricing methodology, which is better suited in today’s dynamic business environment. Design/methodology/approach The authors use a conceptual approach in developing theoretical justifications and show, practically, how a transfer price can be developed using two different real options pricing models. Findings The authors find that real options transfer price mechanism (real options framework [ROF]) can effectively deal with many of the issues that permeate a modern organization with complex multi-dimensional operations. The authors argue that uncertainty and behavioral issues commonly associated with setting transfer prices are better handled using a transfer pricing mechanism that preserves flexibility at the business unit level, the managerial level and the firm level. The approach allows for different managerial styles in both centralized and decentralized sub-units within the same organization. The authors argue that an open multi-dimensional framework using real options is suitable under conditions of uncertainty and managerial opportunism. Practical implications ROF-based transfer pricing may be significant in that firms can use it as a tool to manage an organization by setting the prices centrally and at the same time allowing managers to select the transfer price that best suits their specific situation and operating conditions. This may result in a more efficient and more profitable organization. Originality/value The contribution of the paper is the melding of the ROF from the finance literature with the accounting problem of setting a transfer price for items lacking a competitive market price. The authors also contribute to existing research by explicitly developing a framework that values managerial flexibility, takes into account uncertainty and considers the behavioral aspects of the transfer pricing process. The authors establish the conditions under which a generic real options model is a feasible alternative in determining a transfer price.

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