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Transfer pricing of intrafirm sales as a profit shifting channel: evidence from German firm data

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  • Overesch, Michael

Abstract

This paper investigates whether transfer pricing of intrafirm sales within multinationals represents an important channel of company tax planning. A simple theoretical model, considering profit shifting activities of a multinational company, is used to obtain empirical implications. The empirical analysis, based on a panel of German multinationals, considers directly the supposed tax response of intrafirm sales. The analysis shows a significantly negative impact of the local tax rate on the size of balance sheet items, which reflect intrafirm sales. Thus, the results suggest that transfer pricing of intrafirm sales constitutes an important channel of companies? profit shifting activities.

Suggested Citation

  • Overesch, Michael, 2006. "Transfer pricing of intrafirm sales as a profit shifting channel: evidence from German firm data," ZEW Discussion Papers 06-084, ZEW - Leibniz Centre for European Economic Research.
    • Handle: RePEc:zbw:zewdip:5477
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    References listed on IDEAS

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    12. Jacob, J, 1996. "Taxes and transfer pricing: Income shifting and the volume of intrafirm transfers," Journal of Accounting Research, Wiley Blackwell, vol. 34(2), pages 301-312.
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    18. Hines, James R. Jr., 1999. "Lessons from Behavioral Responses to International Taxation," National Tax Journal, National Tax Association, vol. 52(n. 2), pages 305-22, June.
    Full references (including those not matched with items on IDEAS)

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    Cited by:

    1. Dischinger, Matthias, 2007. "Profit Shifting by Multinationals: Indirect Evidence from European Micro Data," Discussion Papers in Economics 2029, University of Munich, Department of Economics.
    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. Rathke, Alex A.T., 2019. "Fuzzy Profit Shifting: A Model for Optimal Tax-induced Transfer Pricing with Fuzzy Arm's Length Parameter," MPRA Paper 91425, University Library of Munich, Germany.
    4. Giorgia Maffini & Socrates Mokkas, 2009. "Profit Shifting and Measured Productivity of Multinational Firms," Working Papers 0920, Oxford University Centre for Business Taxation.
    5. Gebhardt Heinz & Siemers Lars-H. R., 2017. "Die relative Steuerbelastung mittelständischer Kapitalgesellschaften: Evidenz von handelsbilanziellen Mikrodaten," Zeitschrift für Wirtschaftspolitik, De Gruyter, vol. 66(1), pages 1-35, April.
    6. Giorgia Maffini & Socrates Mokkas, 2008. "Transfer-pricing and Measured Productivity of Multinational Firms," Working Papers 0817, Oxford University Centre for Business Taxation.
    7. Holzmann, Carolin Maria, 2016. "Transfer pricing as tax avoidance under different legislative schemes," VfS Annual Conference 2016 (Augsburg): Demographic Change 145929, Verein für Socialpolitik / German Economic Association.
    8. Johannes Becker, 2014. "Strategic Trade Policy through the Tax System," The World Economy, Wiley Blackwell, vol. 37(9), pages 1237-1246, September.
    9. Dischinger, Matthias, 2010. "Multinational Enterprises and Corporate Taxation," Munich Dissertations in Economics 11147, University of Munich, Department of Economics.
    10. Rathke, Alex Augusto Timm & Rezende, Amaury José, 2016. "Exploring the characteristics of transfer pricing systems across countries," MPRA Paper 70437, University Library of Munich, Germany.
    11. Rathke, Alex A.T. & Rezende, Amaury J. & Watrin, Christoph, 2020. "Classification of transfer pricing systems across countries," International Economics, Elsevier, vol. 164(C), pages 151-167.
    12. V. Vicard, 2015. "Profit shifting through transfer pricing: evidence from French firm level trade data," Working papers 555, Banque de France.
    13. Leibrecht, Markus & Rixen, Thomas, 2020. "Double Tax Avoidance and Tax Competition for Mobile Capital," SocArXiv dgw5k, Center for Open Science.
    14. Rathke, Alex Augusto Timm & Rezende, Amaury José, 2016. "Exploring the characteristics of transfer pricing systems across countries," EconStor Preprints 130141, ZBW - Leibniz Information Centre for Economics.
    15. Hebous, Shafik & Johannesen, Niels, 2021. "At your service! The role of tax havens in international trade with services," European Economic Review, Elsevier, vol. 135(C).
    16. Ji Lee, Ye & Seon Yoo, Ji, 2023. "Loss expectation and income shifting," Journal of Contemporary Accounting and Economics, Elsevier, vol. 19(2).
    17. Alex A. T. Rathke, 2019. "Fuzzy Profit Shifting: A Model for Optimal Tax-induced Transfer Pricing with Fuzzy Arm's Length Parameter," Papers 1901.03843, arXiv.org.
    18. repec:otg:wpaper:1403 is not listed on IDEAS

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    More about this item

    Keywords

    Taxation; Multinationals; Profit Shifting; Transfer Pricing; Firm-level Data;
    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
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance

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