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Inconsistent Transfer Prices And The Location Of Mobile Capital

  • De Waegenaere, Anja
  • Sansing, Richard

We investigate the effects of inconsistent transfer prices on the location and efficiency of capital investments made by multinational firms in a competitive equilibrium. Inconsistent transfer prices create the potential for double taxation. We examine the effects of inconsistent transfer prices on production decisions, production efficiency, and repatriation behavior. We also show how transfer price inconsistency affects the consequences of U.S. tax policy choices relating to the corporate income tax rate, deferral of U.S. taxation of active foreign source income, and the taxation of foreign income on a territorial basis instead of a worldwide basis.

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Article provided by National Tax Association in its journal National Tax Journal.

Volume (Year): 63 (2010)
Issue (Month): 4 (December)
Pages: 1085-1109

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Handle: RePEc:ntj:journl:v:63:y:2010:i:4:p:1085-1109
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  1. Rosanne Altshuler & Harry Grubert, 2002. "Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy," Departmental Working Papers 200009, Rutgers University, Department of Economics.
  2. De Waegenaere, Anja & Sansing, Richard & Wielhouwer, Jacco L., 2007. "Using Bilateral Advance Pricing Agreements to Resolve Tax Transfer Pricing Disputes," National Tax Journal, National Tax Association, vol. 60(2), pages 173-91, June.
  3. James R. Hines, Jr. & Eric M. Rice, 1990. "Fiscal Paradise: Foreign Tax Havens and American Business," NBER Working Papers 3477, National Bureau of Economic Research, Inc.
  4. Anand, Bharat N. & Sansing, Richard, 2000. "The Weighting Game: Formula Apportionment as an Instrument of Public Policy," National Tax Journal, National Tax Association, vol. 53(n. 2), pages 183-200, June.
  5. Elitzur, Ramy & Mintz, Jack, 1996. "Transfer pricing rules and corporate tax competition," Journal of Public Economics, Elsevier, vol. 60(3), pages 401-422, June.
  6. James R. Hines Jr., 1992. "Credit and Deferral as International Investment Incentives," NBER Working Papers 4191, National Bureau of Economic Research, Inc.
  7. Desai, Mihir A. & Hines, James R. Jr., 2004. "Old Rules and New Realities: Corporate Tax Policy in a Global Setting," National Tax Journal, National Tax Association, vol. 57(4), pages 937-60, December.
  8. Hartman, David G., 1985. "Tax policy and foreign direct investment," Journal of Public Economics, Elsevier, vol. 26(1), pages 107-121, February.
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