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Globalization, Multinationals and Tax Base Allocation: Advance Pricing Agreements as Shifts in International Taxation?

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Author Info
Brem Markus
Abstract

This paper elaborates on the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. It refers to how globalizing business processes trigger governance change on the nation state level regarding the identification and allocation of the tax base of multinational companies. The introduction of APA programs and the generation of APAs are considered to be an example of such governance change. On the basis of a governance choice model, the paper seeks to identify factors which might explain variation in the evolution of national APA programs and the implementation of individual APAs between the taxpayer and the tax authorities. Differences in institutions, economic conditions, and the actors involved are important in explaining variation across countries.

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File URL: http://www.iimahd.ernet.in/publications/data/2005-12-01.pdf
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Publisher Info
Paper provided by Indian Institute of Management Ahmedabad, Research and Publication Department in its series IIMA Working Papers with number 2005-12-01.

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Length: 33
Date of creation: 05 Dec 2005
Date of revision:
Handle: RePEc:iim:iimawp:2005-12-01

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Related research
Keywords: Advance pricing agreement; multinational companies; transfer pricing; international taxation; cooperation; non-bureaucratic; governance choice.;

Find related papers by JEL classification:
F02 - International Economics - - General - - - International Economic Order; Noneconomic International Organizations;; Economic Integration and Globalization: General

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References listed on IDEAS
Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.:
  1. Oliver Hart & John Moore, 1999. "On the Design of Hierarchies: Coordination Versus Specialization," NBER Working Papers 7388, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  2. Michael P. Devereux & R. Glenn Hubbard, 2000. "Taxing Multinationals," NBER Working Papers 7920, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  3. Eric J. Bartelsman & Roel M.W.J. Beetsma, 2000. "Why pay more? Corporate Tax Avoidance through Transfer Pricing in OECD Countries," Tinbergen Institute Discussion Papers 00-054/2, Tinbergen Institute. [Downloadable!]
  4. John Whalley, 2001. "Puzzles Over International Taxation of Cross Border Flows of Capital Income," NBER Working Papers 8662, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  5. North, Douglass C, 1991. "Institutions," Journal of Economic Perspectives, American Economic Association, vol. 5(1), pages 97-112, Winter. [Downloadable!] (restricted)
  6. Brem Markus & Tucha Thomas, 2005. "On Transfer Pricing: Conceptual Thoughts on the Nature of the Multinational Firm," IIMA Working Papers 2005-11-03, Indian Institute of Management Ahmedabad, Research and Publication Department. [Downloadable!]
  7. Williamson, Oliver E, 1999. "Public and Private Bureaucracies: A Transaction Cost Economics Perspective," Journal of Law, Economics and Organization, Oxford University Press, vol. 15(1), pages 306-42, April.
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