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Inconsistent Transfer Prices and the Location of Mobile Capital

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  • De Waegenaere, Anja
  • Sansing, Richard

Abstract

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.

Suggested Citation

  • De Waegenaere, Anja & Sansing, Richard, 2010. "Inconsistent Transfer Prices and the Location of Mobile Capital," National Tax Journal, National Tax Association;National Tax Journal, vol. 63(4), pages 1085-1109, December.
    • Handle: RePEc:ntj:journl:v:63:y:2010:i:4:p:1085-1109
    DOI: 10.17310/ntj.2010.4S.11
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    References listed on IDEAS

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    1. Altshuler, Rosanne & Grubert, Harry, 2003. "Repatriation taxes, repatriation strategies and multinational financial policy," Journal of Public Economics, Elsevier, vol. 87(1), pages 73-107, January.
    2. 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;National Tax Journal, vol. 57(4), pages 937-960, December.
    3. Elitzur, Ramy & Mintz, Jack, 1996. "Transfer pricing rules and corporate tax competition," Journal of Public Economics, Elsevier, vol. 60(3), pages 401-422, June.
    4. Hines, James Jr., 1994. "Credit and deferral as international investment incentives," Journal of Public Economics, Elsevier, vol. 55(2), pages 323-347, October.
    5. Hartman, David G., 1985. "Tax policy and foreign direct investment," Journal of Public Economics, Elsevier, vol. 26(1), pages 107-121, February.
    6. James R. Hines & Eric M. Rice, 1994. "Fiscal Paradise: Foreign Tax Havens and American Business," The Quarterly Journal of Economics, Oxford University Press, vol. 109(1), pages 149-182.
    7. 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.
    8. Anja De Waegenaere & Richard C. Sansing & Jacco L. Wielhouwer, 2006. "Who Benefits from Inconsistent Multinational Tax Transfer†Pricing Rules?," Contemporary Accounting Research, John Wiley & Sons, vol. 23(1), pages 103-131, March.
    9. 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;National Tax Journal, vol. 60(2), pages 173-191, June.
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