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Determining appropriate international transfer prices: Economic and administrative rationales for using asset-based profit splits under section 482 of the U.S. tax code

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  • Klemm, Rebecca J.
  • Dwyer, Douglas W.
  • Brewer, Thomas L.
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    Article provided by Elsevier in its journal Global Finance Journal.

    Volume (Year): 6 (1995)
    Issue (Month): 2 ()
    Pages: 111-119

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    Handle: RePEc:eee:glofin:v:6:y:1995:i:2:p:111-119

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    Web page: http://www.elsevier.com/locate/inca/620162

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    1. Dworin, Lowell, 1990. "Transfer Pricing Issues," National Tax Journal, National Tax Association, National Tax Association, vol. 43(3), pages 285-91, September.
    2. E. J. R. Booth & Oscar W. Jensen, 1977. "Transfer Prices in the Global Corporation under Internal and External Constraints," Canadian Journal of Economics, Canadian Economics Association, Canadian Economics Association, vol. 10(3), pages 434-46, August.
    3. Prusa, Thomas J., 1990. "An incentive compatible approach to the transfer pricing problem," Journal of International Economics, Elsevier, Elsevier, vol. 28(1-2), pages 155-172, February.
    4. L. W. Copithorne, 1971. "International Corporate Transfer Prices and Government Policy," Canadian Journal of Economics, Canadian Economics Association, Canadian Economics Association, vol. 4(3), pages 324-41, August.
    5. Itagaki, Takao, 1989. "The multinational enterprise under the threats of restriction on profit repatriation and exchange control," Journal of Development Economics, Elsevier, Elsevier, vol. 31(2), pages 369-377, October.
    6. Gordon, Roger H & Wilson, John Douglas, 1986. "An Examination of Multijurisdictional Corporate Income Taxation under Formula Apportionment," Econometrica, Econometric Society, Econometric Society, vol. 54(6), pages 1357-73, November.
    7. Lall, Sanjaya, 1973. "Transfer-Pricing by Multinational Manufacturing Firms," Oxford Bulletin of Economics and Statistics, Department of Economics, University of Oxford, Department of Economics, University of Oxford, vol. 35(3), pages 173-95, August.
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