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International Transfer Pricing for Goods and Intangible Asset Licenses in a Decentralized Multinational Corporation: Review and Extensions

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Author Info
Peter C. Dawson () (Dallas, Texas)
Stephen M. Miller () (Department of Economics, University of Nevada, Las Vegas)

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Abstract

We review and extend the core literature on international transfer price manipulation to avoid or evade taxes. Under negotiated transfer pricing with a viable bargaining structure, including performance evaluation disconnected from the transfer price, divisions voluntarily exchange accurate information to obtain firm-wide optimality, a result not dependent on restraint from exercising internal market power. For intangible licenses, a larger optimal profit shift for a given tax rate change strengthens incentives for transfer pricing abuse. In practice, an intangible’s arm’s length range is viewed as a guideline, a context where incentives for abuse materialize. Transfer pricing for intangibles obliges greater tax authority scrutiny.

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File URL: http://www.unlv.edu/projects/RePEc/pdf/0901.pdf
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File Function: First version, 2009
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Publisher Info
Paper provided by University of Nevada, Las Vegas , Department of Economics in its series Working Papers with number 0901.

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Length: 57 pages
Date of creation: Jan 2009
Date of revision:
Handle: RePEc:nlv:wpaper:0901

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Related research
Keywords: Negotiated transfer pricing; licensing intangibles; decentralized MNC.;

Other versions of this item:

Find related papers by JEL classification:
F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion
L29 - Industrial Organization - - Firm Objectives, Organization, and Behavior - - - Other
O34 - Economic Development, Technological Change, and Growth - - Technological Change - - - Intellectual Property Rights

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References listed on IDEAS
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  1. Schjelderup, Guttorm & Sorgard, Lars, 1995. "The Multinational Firm, Transfer Pricing and the Nature of Competition," CESifo Working Paper Series CESifo Working Paper No. , CESifo Group Munich.
  2. Vaysman, Igor, 1998. "A model of negotiated transfer pricing," Journal of Accounting and Economics, Elsevier, vol. 25(3), pages 349-384, June. [Downloadable!] (restricted)
  3. Jean-Thomas Bernard & Robert J. Weiner, 1989. "Multinational Corporations, Transfer Prices, and Taxes: Evidence from the U.S. Petroleum Industry," NBER Working Papers 3013, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  4. Kant, Chander, 1988. "Endogenous transfer pricing and the effects of uncertain regulation," Journal of International Economics, Elsevier, vol. 24(1-2), pages 147-157, February. [Downloadable!] (restricted)
  5. James R. Hines, Jr. & Eric M. Rice, 1994. "Fiscal Paradise: Foreign Tax Havens and American Business," NBER Working Papers 3477, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
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  6. Jack Hirshleifer, 1956. "On the Economics of Transfer Pricing," Journal of Business, University of Chicago Press, vol. 29, pages 172. [Downloadable!]
  7. 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. [Downloadable!] (restricted)
  8. Horst, Thomas, 1971. "The Theory of the Multinational Firm: Optimal Behavior under Different Tariff and Tax Rates," Journal of Political Economy, University of Chicago Press, vol. 79(5), pages 1059-72, Sept.-Oct. [Downloadable!] (restricted)
  9. 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, vol. 10(3), pages 434-46, August. [Downloadable!] (restricted)
  10. L. W. Copithorne, 1971. "International Corporate Transfer Prices and Government Policy," Canadian Journal of Economics, Canadian Economics Association, vol. 4(3), pages 324-41, August. [Downloadable!] (restricted)
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