IDEAS home Printed from https://ideas.repec.org/a/eee/aosoci/v33y2008i6p603-628.html
   My bibliography  Save this article

Management control in the transfer pricing tax compliant multinational enterprise

Author

Listed:
  • Cools, Martine
  • Emmanuel, Clive
  • Jorissen, Ann

Abstract

This paper studies the impact of transfer pricing tax compliance on management control system (MCS) design and use within one multinational enterprise (MNE) which employed the same transfer prices for tax compliance and internal management purposes. Our analysis shows immediate effects of tax compliance on the design of organising controls with subsequent effects on planning, evaluating and rewarding controls which reveal a more coercive use of the MCS overall. We argue that modifications to the MCS cannot be understood without an appreciation of the MNEs' fiscal transfer pricing compliance process.

Suggested Citation

  • 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.
    • Handle: RePEc:eee:aosoci:v:33:y:2008:i:6:p:603-628
    as

    Download full text from publisher

    File URL: http://www.sciencedirect.com/science/article/pii/S0361-3682(07)00044-X
    Download Restriction: Full text for ScienceDirect subscribers only
    ---><---

    As the access to this document is restricted, you may want to search for a different version of it.

    References listed on IDEAS

    as
    1. Briers, Michael & Hirst, Mark, 1990. "The role of budgetary information in performance evaluation," Accounting, Organizations and Society, Elsevier, vol. 15(4), pages 373-398.
    2. Merchant, Kenneth A., 1985. "Organizational controls and discretionary program decision making: A field study," Accounting, Organizations and Society, Elsevier, vol. 10(1), pages 67-85, January.
    3. Swenson, Deborah L., 2001. "Tax Reforms and Evidence of Transfer Pricing," National Tax Journal, National Tax Association;National Tax Journal, vol. 54(1), pages 7-26, March.
    4. Holmstrom, Bengt & Tirole, Jean, 1991. "Transfer Pricing and Organizational Form," The Journal of Law, Economics, and Organization, Oxford University Press, vol. 7(2), pages 201-228, Fall.
    5. Thomas Ahrens & Christopher S. Chapman, 2004. "Accounting for Flexibility and Efficiency: A Field Study of Management Control Systems in a Restaurant Chain," Contemporary Accounting Research, John Wiley & Sons, vol. 21(2), pages 271-301, June.
    6. Swieringa, Robert J. & Waterhouse, John H., 1982. "Organizational views of transfer pricing," Accounting, Organizations and Society, Elsevier, vol. 7(2), pages 149-165, April.
    7. Ghosh, Dipankar, 2000. "Complementary arrangements of organizational factors and outcomes of negotiated transfer price," Accounting, Organizations and Society, Elsevier, vol. 25(7), pages 661-682, October.
    8. Cravens, Karen S., 1997. "Examining the role of transfer pricing as a strategy for multinational firms," International Business Review, Elsevier, vol. 6(2), pages 127-145, April.
    9. Abernethy, Margaret A. & Lillis, Anne M., 1995. "The impact of manufacturing flexibility on management control system design," Accounting, Organizations and Society, Elsevier, vol. 20(4), pages 241-258, May.
    10. Luft, Joan & Shields, Michael D., 2003. "Mapping management accounting: graphics and guidelines for theory-consistent empirical research," Accounting, Organizations and Society, Elsevier, vol. 28(2-3), pages 169-249.
    11. Jacob, J, 1996. "Taxes and transfer pricing: Income shifting and the volume of intrafirm transfers," Journal of Accounting Research, Wiley Blackwell, vol. 34(2), pages 301-312.
    12. Picciotto, Sol, 1992. "International taxation and intrafirm pricing in transnational corporate groups," Accounting, Organizations and Society, Elsevier, vol. 17(8), pages 759-792, November.
    13. Grubert, Harry & Mutti, John, 1991. "Taxes, Tariffs and Transfer Pricing in Multinational Corporate Decision Making," The Review of Economics and Statistics, MIT Press, vol. 73(2), pages 285-293, May.
    14. Charles E. Hyde & Chongwoo Choe, 2005. "Keeping Two Sets of Books: The Relationship Between Tax and Incentive Transfer Prices," Journal of Economics & Management Strategy, Wiley Blackwell, vol. 14(1), pages 165-186, March.
    15. Gupta, Sanjay & Mills, Lillian F., 2002. "Corporate multistate tax planning: benefits of multiple jurisdictions," Journal of Accounting and Economics, Elsevier, vol. 33(1), pages 117-139, February.
    16. Simons, Robert, 1990. "The role of management control systems in creating competitive advantage: New perspectives," Accounting, Organizations and Society, Elsevier, vol. 15(1-2), pages 127-143.
    17. Demski, Js, 1976. "Uncertainty And Evaluation Based On Controllable Performance," Journal of Accounting Research, Wiley Blackwell, vol. 14(2), pages 230-245.
    18. Colbert, Gary J. & Spicer, Barry H., 1995. "A multi-case investigation of a theory of the transfer pricing process," Accounting, Organizations and Society, Elsevier, vol. 20(6), pages 423-456, August.
    19. M. Harris & C. H. Kriebel & A. Raviv, 1982. "Asymmetric Information, Incentives and Intrafirm Resource Allocation," Management Science, INFORMS, vol. 28(6), pages 604-620, June.
    20. Cravens, Karen S. & Shearon, Winston Jr., 1996. "An outcome-based assessment of international transfer pricing policy," The International Journal of Accounting, Elsevier, vol. 31(4), pages 419-443.
    21. V. G. Narayanan & Michael Smith, 2000. "Impact of Competition and Taxes on Responsibility Center Organization and Transfer Prices," Contemporary Accounting Research, John Wiley & Sons, vol. 17(3), pages 497-529, September.
    22. Chenhall, Robert H., 2003. "Management control systems design within its organizational context: findings from contingency-based research and directions for the future," Accounting, Organizations and Society, Elsevier, vol. 28(2-3), pages 127-168.
    23. Luft, Joan & Shields, Michael D., 2003. "Erratum to "Mapping management accounting: graphics and guidelines for theory-consistent empirical research" [Accounting Organizations and Society 28 (2003) 169-249]," Accounting, Organizations and Society, Elsevier, vol. 28(7-8), pages 815-815.
    24. Rockness, Howard O. & Shields, Michael D., 1984. "Organizational control systems in research and development," Accounting, Organizations and Society, Elsevier, vol. 9(2), pages 165-177, June.
    25. Chapman, Christopher S., 1997. "Reflections on a contingent view of accounting," Accounting, Organizations and Society, Elsevier, vol. 22(2), pages 189-205, February.
    26. Harris, Dg, 1993. "The Impact Of United-States Tax-Law Revision On Multinational-Corporations Capital Location And Income-Shifting Decisions," Journal of Accounting Research, Wiley Blackwell, vol. 31, pages 111-140.
    27. Hopwood, Anthony G., 1983. "On trying to study accounting in the contexts in which it operates," Accounting, Organizations and Society, Elsevier, vol. 8(2-3), pages 287-305, May.
    28. John H Dunning, 1980. "Towards an Eclectic Theory of International Production: Some Empirical Tests," Journal of International Business Studies, Palgrave Macmillan;Academy of International Business, vol. 11(1), pages 9-31, March.
    29. Swenson, Deborah L., 2001. "Tax Reforms and Evidence of Transfer Pricing," National Tax Journal, National Tax Association, vol. 54(n. 1), pages 7-26, March.
    30. Otley, David T., 1980. "The contingency theory of management accounting: Achievement and prognosis," Accounting, Organizations and Society, Elsevier, vol. 5(4), pages 413-428, October.
    31. Spicer, Barry H., 1988. "Towards an organizational theory of the transfer pricing process," Accounting, Organizations and Society, Elsevier, vol. 13(3), pages 303-322, April.
    32. Borkowski, Susan C., 1996. "An analysis (meta- and otherwise) of multinational transfer pricing research," The International Journal of Accounting, Elsevier, vol. 31(1), pages 39-53.
    33. Klassen, K & Lang, M & Wolfson, M, 1993. "Geographic Income Shifting By Multinational-Corporations In Response To Tax Rate Changes," Journal of Accounting Research, Wiley Blackwell, vol. 31, pages 141-173.
    34. Eden, Lorraine & Dacin, M. Tina & Wan, William P., 2001. "Standards across borders: crossborder diffusion of the arm's length standard in North America," Accounting, Organizations and Society, Elsevier, vol. 26(1), pages 1-23, January.
    35. Jones, C. S., 1985. "An empirical study of the evidence for contingency theories of management accounting systems in conditions of rapid change," Accounting, Organizations and Society, Elsevier, vol. 10(3), pages 303-328, July.
    Full references (including those not matched with items on IDEAS)

    Citations

    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.
    as


    Cited by:

    1. Botzem, Sebastian & Dobusch, Leonhard, 2017. "Financialization as strategy: Accounting for inter-organizational value creation in the European real estate industry," Accounting, Organizations and Society, Elsevier, vol. 59(C), pages 31-43.
    2. Hemling, Lars & Plesner Rossing, Jacob Christian & Hoffjan, Andreas, 2022. "The use of information technology for international transfer pricing in multinational enterprises," International Journal of Accounting Information Systems, Elsevier, vol. 44(C).
    3. Martina Sageder & Birgit Feldbauer-Durstmüller, 2019. "Management control in multinational companies: a systematic literature review," Review of Managerial Science, Springer, vol. 13(5), pages 875-918, November.
    4. da Silva Stefano, Gustavo & Antunes, Tiago dos Santos & Lacerda, Daniel Pacheco & Wolf Motta Morandi, Maria Isabel & Piran, Fabio Sartori, 2022. "The impacts of inventory in transfer pricing and net income: Differences between traditional accounting and throughput accounting," The British Accounting Review, Elsevier, vol. 54(2).
    5. Sikka, Prem & Willmott, Hugh, 2010. "The dark side of transfer pricing: Its role in tax avoidance and wealth retentiveness," CRITICAL PERSPECTIVES ON ACCOUNTING, Elsevier, vol. 21(4), pages 342-356.
    6. Rebecca Reineke & Katrin Weiskirchner-Merten & Stefan Wielenberg, 2023. "When do firms use one set of books in an international tax compliance game?," Review of Accounting Studies, Springer, vol. 28(3), pages 1856-1885, September.
    7. Plesner Rossing, Christian & Cools, Martine & Rohde, Carsten, 2017. "International transfer pricing in multinational enterprises," Journal of Accounting Education, Elsevier, vol. 39(C), pages 55-67.
    8. Bisbe, Josep & Kruis, Anne-Marie & Madini, Paola, 2019. "Coercive, enabling, diagnostic, and interactive control: Untangling the threads of their connections," Journal of Accounting Literature, Elsevier, vol. 43(C), pages 124-144.
    9. Elliot, Viktor, 2018. "Funds Transfer Pricing in Swedish Savings Banks: An Exploratory Survey," Scandinavian Journal of Management, Elsevier, vol. 34(3), pages 289-302.
    10. E. Van Der Hauwaert & W. Bruggeman, 2012. "The balanced scorecard as an enabling technology – the role of participation," Working Papers of Faculty of Economics and Business Administration, Ghent University, Belgium 12/816, Ghent University, Faculty of Economics and Business Administration.
    11. Plesner Rossing, Jacob Christian & Pearson, Thomas C., 2022. "Tax-compliant transfer pricing of intra-group services: The soft drink case," Journal of Accounting Education, Elsevier, vol. 61(C).
    12. Mai, Nhat Chi, 2020. "The Effects Of The Base Erosion And Profit Shifting (Beps) Action 13 On Transfer Pricing Practices: A Comparative Empirical Study Of New Zealand And Vietnam," OSF Preprints gq27c, Center for Open Science.

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Cuzdriorean Dan Dacian & Jurcau Anca Sabina, 2009. "Tax Optimization Through Transfer Pricing, Common And Manipulative Practice," Annals of Faculty of Economics, University of Oradea, Faculty of Economics, vol. 3(1), pages 872-876, May.
    2. Mundy, Julia, 2010. "Creating dynamic tensions through a balanced use of management control systems," Accounting, Organizations and Society, Elsevier, vol. 35(5), pages 499-523, July.
    3. Granlund, Markus & Lukka, Kari, 2017. "Investigating highly established research paradigms: Reviving contextuality in contingency theory based management accounting research," CRITICAL PERSPECTIVES ON ACCOUNTING, Elsevier, vol. 45(C), pages 63-80.
    4. Chenhall, Robert H., 2003. "Management control systems design within its organizational context: findings from contingency-based research and directions for the future," Accounting, Organizations and Society, Elsevier, vol. 28(2-3), pages 127-168.
    5. Klaus Derfuss, 2015. "Relating Context Variables to Participative Budgeting and Evaluative Use of Performance Measures: A Meta-analysis," Abacus, Accounting Foundation, University of Sydney, vol. 51(2), pages 238-278, June.
    6. Arnt Ove Hopland & Petro Lisowsky & Mohammed Mardan & Dirk Schindler, 2014. "Income Shifting under Losses," CESifo Working Paper Series 5130, CESifo.
    7. Widener, Sally K., 2004. "An empirical investigation of the relation between the use of strategic human capital and the design of the management control system," Accounting, Organizations and Society, Elsevier, vol. 29(3-4), pages 377-399.
    8. Chenhall, Robert H. & Moers, Frank, 2015. "The role of innovation in the evolution of management accounting and its integration into management control," Accounting, Organizations and Society, Elsevier, vol. 47(C), pages 1-13.
    9. Bhimani, Alnoor & Sivabalan, Prabhu & Soonawalla, Kazbi, 2018. "A study of the linkages between rolling budget forms, uncertainty and strategy," The British Accounting Review, Elsevier, vol. 50(3), pages 306-323.
    10. Arnold, Markus & Artz, Martin, 2019. "The use of a single budget or separate budgets for planning and performance evaluation," Accounting, Organizations and Society, Elsevier, vol. 73(C), pages 50-67.
    11. Davila, Tony, 2005. "An exploratory study on the emergence of management control systems: formalizing human resources in small growing firms," Accounting, Organizations and Society, Elsevier, vol. 30(3), pages 223-248, April.
    12. Gerdin, Jonas & Greve, Jan, 2004. "Forms of contingency fit in management accounting research--a critical review," Accounting, Organizations and Society, Elsevier, vol. 29(3-4), pages 303-326.
    13. Henri, Jean-Francois, 2006. "Management control systems and strategy: A resource-based perspective," Accounting, Organizations and Society, Elsevier, vol. 31(6), pages 529-558, August.
    14. Bisbe, Josep & Batista-Foguet, Joan-Manuel & Chenhall, Robert, 2007. "Defining management accounting constructs: A methodological note on the risks of conceptual misspecification," Accounting, Organizations and Society, Elsevier, vol. 32(7-8), pages 789-820.
    15. Nikolaos Theriou & Vassilis Aggelidis, 2014. "Management Accounting Systems, Top Management Team’s Risk Characteristics and Their Effect on Strategic Change," International Journal of Economics & Business Administration (IJEBA), International Journal of Economics & Business Administration (IJEBA), vol. 0(2), pages 3-38.
    16. Hanlon, Michelle & Heitzman, Shane, 2010. "A review of tax research," Journal of Accounting and Economics, Elsevier, vol. 50(2-3), pages 127-178, December.
    17. Verbeeten, F.H.M., 2005. "New’ Performance Measures: Determinants of Their Use and Their Impact on Performance," ERIM Report Series Research in Management ERS-2005-054-F&A, Erasmus Research Institute of Management (ERIM), ERIM is the joint research institute of the Rotterdam School of Management, Erasmus University and the Erasmus School of Economics (ESE) at Erasmus University Rotterdam.
    18. Carolyn Stringer, 2007. "Empirical performance management research: observations fromAOSandMAR," Qualitative Research in Accounting & Management, Emerald Group Publishing Limited, vol. 4(2), pages 92-114, June.
    19. Annukka Jokipii, 2010. "Determinants and consequences of internal control in firms: a contingency theory based analysis," Journal of Management & Governance, Springer;Accademia Italiana di Economia Aziendale (AIDEA), vol. 14(2), pages 115-144, May.
    20. Hall, Matthew, 2010. "Accounting information and managerial work," LSE Research Online Documents on Economics 28539, London School of Economics and Political Science, LSE Library.

    More about this item

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:eee:aosoci:v:33:y:2008:i:6:p:603-628. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Catherine Liu (email available below). General contact details of provider: http://www.elsevier.com/locate/aos .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.