International Transfer Pricing for Goods and Intangible Asset Licenses in a Decentralized Multinational Corporation: Review and Extensions
AbstractWe 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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Bibliographic InfoPaper provided by University of Nevada, Las Vegas , Department of Economics in its series Working Papers with number 0901.
Length: 57 pages
Date of creation: Jan 2009
Date of revision:
Negotiated transfer pricing; licensing intangibles; decentralized MNC.;
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; Research and Development; Intellectual Property Rights - - - Intellectual Property and Intellectual Capital
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- 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.
- 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.
- Jack Hirshleifer, 1956. "On the Economics of Transfer Pricing," The Journal of Business, University of Chicago Press, vol. 29, pages 172.
- Lall, Sanjaya, 1973. "Transfer-Pricing by Multinational Manufacturing Firms," Oxford Bulletin of Economics and Statistics, Department of Economics, University of Oxford, vol. 35(3), pages 173-95, August.
- Schjelderup, G. & Sorgard, L., 1995. "The Multinational Firn Transfer Pricing and the Natural Competition," Papers 16/95, Norwegian School of Economics and Business Administration-.
- Hines, James R, Jr & Rice, Eric M, 1994.
"Fiscal Paradise: Foreign Tax Havens and American Business,"
The Quarterly Journal of Economics,
MIT Press, vol. 109(1), pages 149-82, February.
- Hines, J.R. & Rice, E.M., 1990. "Fiscal Paradise: Foreign Tax Havens And American Business," Papers 56, Princeton, Woodrow Wilson School - Discussion Paper.
- 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.
- 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.
- Vaysman, Igor, 1998. "A model of negotiated transfer pricing," Journal of Accounting and Economics, Elsevier, vol. 25(3), pages 349-384, June.
- Harris, D. & Morck, R. & Slemrod, J., 1991.
"Income Shifting in U.S. Multinational Corporations,"
287, Research Seminar in International Economics, University of Michigan.
- David Harris & Randall Morck & Joel B. Slemrod, 1993. "Income Shifting in U.S. Multinational Corporations," NBER Chapters, in: Studies in International Taxation, pages 277-308 National Bureau of Economic Research, Inc.
- David Harris & Randall Morck & Joel Slemrod & Bernard Yeung, 1991. "Income Shifting in U.S. Multinational Corporations," NBER Working Papers 3924, National Bureau of Economic Research, Inc.
- Dworin, Lowell, 1990. "Transfer Pricing Issues," National Tax Journal, National Tax Association, vol. 43(3), pages 285-91, September.
- Jerome E. Hass, 1968. "Transfer Pricing in a Decentralized Firm," Management Science, INFORMS, vol. 14(6), pages B310-B331, February.
- 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.
- 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.
- Jean-Thomas Bernard & Robert Weiner, 1990. "Multinational Corporations, Transfer Prices, and Taxes: Evidence from the U.S.Petroleum Industry," NBER Chapters, in: Taxation in the Global Economy, pages 123-160 National Bureau of Economic Research, Inc.
- Bernard, J-T. & Weiner, R.J., 1988. "Multinational Corporations, Transfer Prices, And Taxes: Evidence From The U.S. Petroleum Industry," Papers 8822, Laval - Recherche en Energie.
- 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.
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