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Tax-compliant transfer pricing and responsibility accounting

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Author Info
Cools, M.
Slagmulder, R. (Vlerick Leuven Gent Management School)

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Abstract

While the accounting literature has extensively studied the role of transfer pricing (TP) within the management control system (MCS) of companies, MCS issues related to cross-border transfers have received far less attention. In this case study, we investigate how TP tax compliance influences responsibility accounting when one multinational enterprise (MNE) uses a single set of transfer prices for both tax compliance and management control. First, the MNE eliminated TP negotiation, leading to psychologically disagreeable and sometimes also economically harmful situations. Second, the firm administratively simplified the determination of profit margins to such an extent that it could lead to suboptimal business decisions. Third, tax compliance induced a profit center designation for business units that were primarily responsible for costs or revenues. The firm first coped with a mixed treatment of these responsibility centers, allowing them to be profit centers for tax purposes and cost or revenue centers for MCS purposes. Later, top management became convinced of the benefits of a profit-center treatment for all purposes and started to convert the pro-forma profit centers into real profit centers. Overall, this study contributes to the stream of research documenting and explaining how MCSs are designed and used under environmental pressures.

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Publisher Info
Paper provided by Vlerick Leuven Gent Management School in its series Vlerick Leuven Gent Management School Working Paper Series with number 2009-20.

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Length: 46 pages
Date of creation: 13 Jul 2009
Date of revision:
Handle: RePEc:vlg:vlgwps:2009-20

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Related research
Keywords: international transfer pricing; management control system; responsibility accounting; multinational enterprise.;

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References listed on IDEAS
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  1. Charles E. Hyde & Chongwoo Choe, 2005. "Keeping Two Sets of Books: The Relationship Between Tax and Incentive Transfer Prices," Journal of Economics & Management Strategy, Blackwell Publishing, vol. 14(1), pages 165-186, 03. [Downloadable!] (restricted)
  2. Colbert, Gary J. & Spicer, Barry H., 1995. "A multi-case investigation of a theory of the transfer pricing process," Accounting, Organizations and Society, Elsevier, vol. 20(6), pages 423-456, August. [Downloadable!] (restricted)
  3. Holmstrom, Bengt & Tirole, Jean, 1991. "Transfer Pricing and Organizational Form," Journal of Law, Economics and Organization, Oxford University Press, vol. 7(2), pages 201-28, Fall.
  4. 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)
  5. Cools, Martine & Emmanuel, Clive & Jorissen, Ann, 2008. "Management control in the transfer pricing tax compliant multinational enterprise," Accounting, Organizations and Society, Elsevier, vol. 33(6), pages 603-628, August. [Downloadable!] (restricted)
  6. Cravens, Karen S. & Shearon, Winston Jr., 1996. "An outcome-based assessment of international transfer pricing policy," The International Journal of Accounting, Elsevier, vol. 31(4), pages 419-443. [Downloadable!] (restricted)
  7. Merchant, Kenneth A. & Chow, Chee W. & Wu, Anne, 1995. "Measurement, evaluation and reward of profit center managers: A cross-cultural field study," Accounting, Organizations and Society, Elsevier, vol. 20(7-8), pages 619-638. [Downloadable!] (restricted)
  8. Chenhall, Robert H., 2003. "Management control systems design within its organizational context: findings from contingency-based research and directions for the future," Accounting, Organizations and Society, Elsevier, vol. 28(2-3), pages 127-168. [Downloadable!] (restricted)
  9. Picciotto, Sol, 1992. "International taxation and intrafirm pricing in transnational corporate groups," Accounting, Organizations and Society, Elsevier, vol. 17(8), pages 759-792, November. [Downloadable!] (restricted)
  10. Bengt Holmstrom, 1982. "Moral Hazard in Teams," Bell Journal of Economics, The RAND Corporation, vol. 13(2), pages 324-340, Autumn. [Downloadable!] (restricted)
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