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Transfer Pricing in the Decentralized Multinational Corporation

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Author Info
Peter C. Dawson (Internal Revenue Service, Dallas)
Stephen M. Miller (University of Connecticut)

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Abstract

This paper considers how the multinational corporation's transfer price responds to changes in international corporate effective tax rates. It extends the decentralized decision-making analysis of transfer pricing in the context of different tax rates. It adopts and extends Bond's (1980) model of the decentralized multinational corporation that assumes centralized transfer pricing. The direction of transfer price change is as expected, while the magnitude of change is likely to be less than predicted by the Horst (1971), centralized decision-making model. The paper extends the model further by assuming negotiated transfer pricing, where the analysis is partitioned into perfect and imperfect information cases. The negotiated transfer pricing result reverts to the Horst (1971), or centralized decision-making, result, under perfect information. Under imperfect information, the centralized decision-making result obtains when top management successfully informs division general managers or it successfully implements a non-monetary reward scheme to encourage division general managers to cooperate. Under simplifying assumptions, centralized decision-making dominates decentralized decision-making, while negotiated transfer pricing weakly dominates centralized transfer pricing.

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Paper provided by University of Connecticut, Department of Economics in its series Working papers with number 2000-06.

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Length: 39 pages
Date of creation: Jul 2000
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Handle: RePEc:uct:uconnp:2000-06

Note: The contents of this article are the opinions of the writers and do not necessarily represent the position of the Internal Revenue Service.
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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. 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)
  3. 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)
  4. 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)
  5. Guttorm Schjelderup & Lars Sorgard, 1997. "Transfer Pricing as a Strategic Device for Decentralized Multinationals," International Tax and Public Finance, Springer, vol. 4(3), pages 277-290, July. [Downloadable!] (restricted)
  6. Hoel, Michael, 1991. "Global environmental problems: The effects of unilateral actions taken by one country," Journal of Environmental Economics and Management, Elsevier, vol. 20(1), pages 55-70, January. [Downloadable!] (restricted)
  7. 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)
  8. Chatterjee, Kalyan & Samuelson, Larry, 1987. "Bargaining with Two-Sided Incomplete Information: An Infinite Horizon Model with Alternating Offers," Review of Economic Studies, Blackwell Publishing, vol. 54(2), pages 175-92, April. [Downloadable!] (restricted)
  9. Sopher, Barry, 1993. "A laboratory analysis of bargaining power in a random ultimatum game," Journal of Economic Behavior & Organization, Elsevier, vol. 21(1), pages 69-90, May. [Downloadable!] (restricted)
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