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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Paper provided by University of Nevada, Las Vegas , Department of Economics in its series Working Papers with number
0901.
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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