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Tariff-induced Transfer Pricing and the CCCTB

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  • Ronald B Davies

    (University College Dublin)

Abstract

The common consolidated corporate tax base has been suggested as a way to curb tax avoidance by allocating profits across borders via a formula. This paper demonstrates that when transfer pricing occurs both for tariff and tax minimization, that moving from separate accounting to formula apportionment can actually increase transfer pricing. This, combined with arm's length pricing regulations, can result in lower revenues for high-tax countries and lower overall revenues. This casts additional doubt over whether such a move would have its intended, revenue-enhancing effects.

Suggested Citation

  • Ronald B Davies, 2013. "Tariff-induced Transfer Pricing and the CCCTB," Working Papers 201314, School of Economics, University College Dublin.
    • Handle: RePEc:ucn:wpaper:201314
    as

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    File URL: http://www.ucd.ie/t4cms/WP13_14.pdf
    File Function: First version, 2013
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    References listed on IDEAS

    as
    1. Hines Jr., James R., 2010. "Income misattribution under formula apportionment," European Economic Review, Elsevier, vol. 54(1), pages 108-120, January.
    2. Bruce A. Blonigen & Ronald B. Davies & Glen R. Waddell & Helen T. Naughton, 2019. "FDI in Space: Spatial Autoregressive Relationships in Foreign Direct Investment," World Scientific Book Chapters, in: Foreign Direct Investment, chapter 2, pages 55-88, World Scientific Publishing Co. Pte. Ltd..
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    5. Guttorm Schjelderup & Lars Sorgard, 1997. "Transfer Pricing as a Strategic Device for Decentralized Multinationals," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 4(3), pages 277-290, July.
    6. Eichner, Thomas & Runkel, Marco, 2011. "Corporate income taxation of multinationals in a general equilibrium model," Journal of Public Economics, Elsevier, vol. 95(7), pages 723-733.
    7. Søren Bo Nielsen & Pascalis Raimondos–Møller & Guttorm Schjelderup, 2003. "Formula Apportionment and Transfer Pricing under Oligopolistic Competition," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 5(2), pages 419-437, April.
    8. James R. MARKUSEN, 2021. "Multinationals, Multi-Plant Economies, And The Gains From Trade," World Scientific Book Chapters, in: BROADENING TRADE THEORY Incorporating Market Realities into Traditional Models, chapter 1, pages 3-24, World Scientific Publishing Co. Pte. Ltd..
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    11. Ronald B. Davies, 2008. "Hunting High and Low for Vertical FDI," Review of International Economics, Wiley Blackwell, vol. 16(2), pages 250-267, May.
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    Cited by:

    1. Tatiana Dănescu & Maria Alexandra Botoş, 2018. "Analysis of Companies' Behaviour in Smoothing Conflicts of Interest," Annals of the University of Petrosani, Economics, University of Petrosani, Romania, vol. 18(1), pages 45-56.

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    More about this item

    Keywords

    Common Consolidated Corporate Tax Base; Vertical FDI; Formula Apportionment; Transfer Pricing;
    All these keywords.

    JEL classification:

    • F24 - International Economics - - International Factor Movements and International Business - - - Remittances
    • F36 - International Economics - - International Finance - - - Financial Aspects of Economic Integration
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods

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