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Abusive Transfer Pricing and Economic Activity

Author

Listed:
  • Søren Bo Nielsen
  • Dirk Schindler
  • Guttorm Schjelderup

Abstract

We demonstrate that the choice of the transfer price and its effect on intra-firm trade and investment depends on the probability of detection and thus on the measure, on which tax authorities base their audit. A policy implication of the paper is that it should be preferable to condition audits on the amount of income shifted rather than on the distortion of the transfer price proper. Another policy finding is that improving the quality of tax law might be superior to higher detection effort. The former reduces profit shifting and concealment effort, whereas the latter leads to more wasteful use of resources on concealment and has an ambiguous effect on profits shifted.

Suggested Citation

  • Søren Bo Nielsen & Dirk Schindler & Guttorm Schjelderup, 2014. "Abusive Transfer Pricing and Economic Activity," CESifo Working Paper Series 4975, CESifo.
  • Handle: RePEc:ces:ceswps:_4975
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    References listed on IDEAS

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    1. Bauer, Christian J. & Langenmayr, Dominika, 2013. "Sorting into outsourcing: Are profits taxed at a gorilla's arm's length?," Journal of International Economics, Elsevier, vol. 90(2), pages 326-336.
    2. Allingham, Michael G. & Sandmo, Agnar, 1972. "Income tax evasion: a theoretical analysis," Journal of Public Economics, Elsevier, vol. 1(3-4), pages 323-338, November.
    3. Johannes Becker & Ronald B. Davies, 2014. "A Negotiation-Based Model of Tax-Induced Transfer Pricing," The Institute for International Integration Studies Discussion Paper Series iiisdp451, IIIS.
    4. Atkinson, A. B. & Stiglitz, J. E., 1976. "The design of tax structure: Direct versus indirect taxation," Journal of Public Economics, Elsevier, vol. 6(1-2), pages 55-75.
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    Cited by:

    1. Gresik, Thomas A. & Schindler, Dirk & Schjelderup, Guttorm, 2017. "Immobilizing corporate income shifting: Should it be safe to strip in the harbor?," Journal of Public Economics, Elsevier, vol. 152(C), pages 68-78.
    2. Dominik Boddin & Frank Stähler, 2018. "The Organization of International Trade," CESifo Working Paper Series 7378, CESifo.
    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. Koethenbuerger, Marko & Mardan, Mohammed & Stimmelmayr, Michael, 2019. "Profit shifting and investment effects: The implications of zero-taxable profits," Journal of Public Economics, Elsevier, vol. 173(C), pages 96-112.
    5. Rathke, Alex A.T., 2019. "Fuzzy Profit Shifting: A Model for Optimal Tax-induced Transfer Pricing with Fuzzy Arm's Length Parameter," EconStor Preprints 191027, ZBW - Leibniz Information Centre for Economics.
    6. Jie Ma & Pascalis Raimondos, 2015. "Competition for FDI and Profit Shifting," CESifo Working Paper Series 5153, CESifo.
    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. repec:ces:ifodic:v:12:y:2015:i:4:p:19149986 is not listed on IDEAS
    9. Guttorm Schjelderup, 2016. "The Tax Sensitivity of Debt in Multinationals: A Review," International Journal of the Economics of Business, Taylor & Francis Journals, vol. 23(1), pages 109-121, February.
    10. 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.
    11. Bodo Knoll & Nadine Riedel, 2015. "Transfer Pricing Laws," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(04), pages 22-26, January.
    12. Bodo Knoll & Nadine Riedel, 2015. "Transfer Pricing Laws," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(4), pages 22-26, 01.

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    More about this item

    Keywords

    transfer pricing; investment; concealment costs; economic activity;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies

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