Formula Apportionment and Transfer Pricing under Oligopolistic Competition
This paper demonstrates that under conditions of imperfect (oligopolistic) competition, a transition from separate accounting (SA) to formula apportionment (FA) does not eliminate the problem of profit shifting via transfer pricing. In particular, if affiliates of a multinational firm face oligopolistic competition, it is beneficial for the multinational to manipulate transfer prices for tax-saving as well as strategic reasons under both FA and SA. The analysis shows that a switch from SA rules to FA rules may actually strengthen profit shifting activities by multinationals. Copyright 2003 Blackwell Publishing Inc..
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Volume (Year): 5 (2003)
Issue (Month): 2 (04)
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