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Negotiated Transfer Prices

Author

Listed:
  • Johannes Becker
  • Ronald B. Davies

Abstract

The predominant model of tax induced transfer pricing is based on the assumption that profit shifting is due to insufficient enforcement. However, evidence shows that the firms responsible for most profit shifting are also among the most frequently audited. We present an alternative model based on negotiations that avoid costly, yet uncertain, formal proceedings (e.g. court procedures). This model predicts that profit shifting increases in the tax gap even though enforcement is perfect. Further, it suggests that current efforts to streamline international tax law may have the unintended effect of increasing profit shifting.

Suggested Citation

  • Johannes Becker & Ronald B. Davies, 2015. "Negotiated Transfer Prices," Working Papers 201527, School of Economics, University College Dublin.
    • Handle: RePEc:ucn:wpaper:201527
    as

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    File URL: http://hdl.handle.net/10197/7188
    File Function: First version, 2015
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    References listed on IDEAS

    as
    1. Johannes Becker & Ronald B Davies, 2014. "A negotiation-based model of tax-induced transfer pricing," Working Papers 1409, Oxford University Centre for Business Taxation.
    2. Ronald B. Davies & Julien Martin & Mathieu Parenti & Farid Toubal, 2018. "Knocking on Tax Haven’s Door: Multinational Firms and Transfer Pricing," The Review of Economics and Statistics, MIT Press, vol. 100(1), pages 120-134, March.
    3. Becker, Johannes & Davies, Ronald B. & Jakobs, Gitte, 2017. "The economics of advance pricing agreements," Journal of Economic Behavior & Organization, Elsevier, vol. 134(C), pages 255-268.
    4. Dhammika Dharmapala, 2014. "What Do We Know about Base Erosion and Profit Shifting? A Review of the Empirical Literature," Fiscal Studies, Institute for Fiscal Studies, vol. 35, pages 421-448, December.
    5. Allingham, Michael G. & Sandmo, Agnar, 1972. "Income tax evasion: a theoretical analysis," Journal of Public Economics, Elsevier, vol. 1(3-4), pages 323-338, November.
    6. Becker, Johannes & Fuest, Clemens, 2012. "Transfer pricing policy and the intensity of tax rate competition," Economics Letters, Elsevier, vol. 117(1), pages 146-148.
    Full references (including those not matched with items on IDEAS)

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    More about this item

    Keywords

    Nash bargaining; Transfer pricing; Tax avoidance; Corporate taxation;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods

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