Keeping Two Sets of Books: The Relationship Between Tax and Incentive Transfer Prices
AbstractMultinational enterprises use two types of transfer prices: the tax transfer price to achieve optimal tax outcomes and the incentive transfer price to provide appropriate incentives to offshore managers. The two optimal transfer prices are independent if taxable income is assessed using the formula apportionment approach. Under the separate entity approach, however, they are interdependent: they both decrease as the penalty for noncompliance with the arm's length principle increases; and the tax transfer price decreases and the incentive transfer price increases as the marginal cost of production increases. We also examine the case where the incentive transfer price is negotiated rather than dictated by the parent. The results are robust to different market structures and tax environments. Copyright Blackwell Publishing 2005.
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Bibliographic InfoArticle provided by Wiley Blackwell in its journal Journal of Economics & Management Strategy.
Volume (Year): 14 (2005)
Issue (Month): 1 (03)
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- Chongwoo Choe & Noriaki Matsushima, 2012.
"The Arm’s Length Principle and Tacit Collusion,"
Monash Economics Working Papers
02-12, Monash University, Department of Economics.
- Martini, Jan Thomas & Niemann, Rainer & Simons, Dirk, 2007. "Transfer pricing or formula apportionment? Tax-induced distortions of multinationals' investment and production decisions," arqus Discussion Papers in Quantitative Tax Research 27, arqus - Arbeitskreis Quantitative Steuerlehre.
- A. Lemus & Diego Moreno, 2011. "The non-neutrality of the arm's length principle with imperfect competition," Economics Working Papers we1134, Universidad Carlos III, Departamento de Economía.
- Devereux, Michael P. & Keuschnigg, Christian, 2009.
"The Distorting Arm's Length Principle,"
CEPR Discussion Papers
7375, C.E.P.R. Discussion Papers.
- Christian Keuschnigg & Michael P. Devereux, 2009. "The Distorting Arm's Length Principle," University of St. Gallen Department of Economics working paper series 2009 2009-20, Department of Economics, University of St. Gallen.
- Michael P. Devereux & Christian Keuschnigg, 2009. "The Distorting Arm’s Length Principle," Working Papers 0910, Oxford University Centre for Business Taxation.
- Nielsen, Søren Bo & Raimondos-Møller, Pascalis & Schjelderup, Guttorm, 2007.
"Taxes and Decision Rights in Multinationals,"
2007/11, Department of Business and Management Science, Norwegian School of Economics.
- Nielsen, Soren Bo & Raimondos-Møller, Pascalis & Schjelderup, Guttorm, 2006. "Taxes and Decision Rights in Multinationals," CEPR Discussion Papers 5952, C.E.P.R. Discussion Papers.
- Nielsen, Søren Bo & Raimondos-Møller, Pascalis & Schjelderup, Guttorm, 2006. "Taxes and Decision Rights in Multinationals," Working Papers 07-2006, Copenhagen Business School, Department of Economics.
- Keuschnigg, Christian & Devereux, Michael P., 2013. "The arm's length principle and distortions to multinational firm organization," Journal of International Economics, Elsevier, vol. 89(2), pages 432-440.
- Kristian Behrens & Susana Peralta & Pierre M. Picard, 2009.
"Transfer Pricing Rules, OECD Guidelines, and Market Distortions,"
Cahiers de recherche
- BEHRENS, Kristian & PERALTA, Susana & PICARD, Pierre, 2009. "Transfer pricing rules, OECD guidelines, and market distortions," CORE Discussion Papers 2009067, Université catholique de Louvain, Center for Operations Research and Econometrics (CORE).
- Kristian Behrens & Susana Peralta & Pierre M. Picard, 2010. "Transfer pricing rules, OECD guidelines, and market distortions," CREA Discussion Paper Series 10-20, Center for Research in Economic Analysis, University of Luxembourg.
- Cools, Martine & Emmanuel, Clive & Jorissen, Ann, 2008. "Management control in the transfer pricing tax compliant multinational enterprise," Accounting, Organizations and Society, Elsevier, vol. 33(6), pages 603-628, August.
- Andrew B. Bernard & J. Bradford Jensen & Peter K. Schott, 2006.
"Transfer Pricing by U.S.-Based Multinational Firms,"
NBER Working Papers
12493, National Bureau of Economic Research, Inc.
- Andrew Bernard & J. Bradford Jensen & Peter Schott, 2008. "Transfer Pricing by U.S.-Based Multinational Firms," Working Papers 08-29, Center for Economic Studies, U.S. Census Bureau.
- Chongwoo Choe & Charles E. Hyde, 2007. "Multinational Transfer Pricing, Tax Arbitrage and the Arm's Length Principle," The Economic Record, The Economic Society of Australia, vol. 83(263), pages 398-404, December.
- Ana B. Lemus, 2011. "Strategic incentives for kepping one set of books under the Arm's Length Principle," Economics Working Papers we1135, Universidad Carlos III, Departamento de Economía.
- Jan Thomas Martini & Rainer Niemann & Dirk Simons, 2007. "Transfer Pricing or Formula Apportionment? Tax-Induced Distortions of Multinationals’ Investment and Production Decisions," CESifo Working Paper Series 2020, CESifo Group Munich.
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