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The Economics of Advance Pricing Agreements

Author

Listed:
  • Johannes Becker
  • Ronald B. Davies
  • Gitte Jakobs

Abstract

Advance pricing agreements (APAs) determine transfer prices for intra-firm transactions in advance. This paper interprets these contracts as a means to overcome a hold-up problem that occurs because governments cannot commit to non-excessive future tax rates. In addition, with private information, just as in practice, our APAs will be complex and require lengthy negotiations. Nevertheless, implemented APAs lead to a Pareto improvement even when all agents are risk neutral. However, not all efficient APAs are concluded in equilibrium. International agreements to avoid double taxation will likely reduce the number of realized APAs.

Suggested Citation

  • Johannes Becker & Ronald B. Davies & Gitte Jakobs, 2014. "The Economics of Advance Pricing Agreements," CESifo Working Paper Series 5079, CESifo.
    • Handle: RePEc:ces:ceswps:_5079
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    References listed on IDEAS

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    11. Tomohara, Akinori, 2004. "Inefficiencies of Bilateral Advanced Pricing Agreements (BAPA) in Taxing Multinational Companies," National Tax Journal, National Tax Association;National Tax Journal, vol. 57(4), pages 863-873, December.
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    Cited by:

    1. Johannes Becker & Ronald B. Davies, 2015. "Negotiated Transfer Prices," Working Papers 201527, School of Economics, University College Dublin.
    2. Chen, An & Hieber, Peter & Sureth, Caren, 2022. "Pay for tax certainty? Advance tax rulings for risky investment under multi-dimensional tax uncertainty," arqus Discussion Papers in Quantitative Tax Research 273, arqus - Arbeitskreis Quantitative Steuerlehre.
    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. Alex A. T. Rathke & Amaury J. Rezende & Christoph Watrin & Rafael M. Antônio, 2023. "Profit shifting and the attractiveness of Advance Pricing Agreements," Journal of Business Economics, Springer, vol. 93(5), pages 817-857, July.
    5. 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.
    6. Thomas Tørsløv & Ludvig Wier & Gabriel Zucman, 2023. "Externalities in International Tax Enforcement: Theory and Evidence," American Economic Journal: Economic Policy, American Economic Association, vol. 15(2), pages 497-525, May.
    7. 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.

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    More about this item

    Keywords

    advance pricing agreements; corporate taxation; multinational firms; transfer pricing;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • M41 - Business Administration and Business Economics; Marketing; Accounting; Personnel Economics - - Accounting - - - Accounting
    • G32 - Financial Economics - - Corporate Finance and Governance - - - Financing Policy; Financial Risk and Risk Management; Capital and Ownership Structure; Value of Firms; Goodwill

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