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Addressing the Transfer-Pricing Problem in an Origin-Basis X Tax

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  • David Bradford

Abstract

In a previous paper I described how the tax design called the X Tax would facilitate an international tax system free of many of the complexities and avoidance opportunities plaguing the existing international tax regime and also have neutrality properties generally deemed desirable. A choice must, however, be made between two basic treatments of transborder business transactions – the origin and destination principles. The destination-principle approach sidesteps the need to identify arm’s length terms of transborder transactions between related business entities – the transfer-pricing problem. This serious problem remains in the origin-principle approach, which, however, presents fewer challenges of monitoring the flow of goods and services across borders, obviates what I call the “tourism problem” whereby people can reduce their taxes by consuming in a low-tax jurisdiction and, arguably most important, avoids transition effects associated with introduction of the tax and subsequent tax rate changes that occur in the destination approach. In this paper I explore possible special rules for transborder transactions between related parties in an origin-based system to eliminate the transferpricing problem.

Suggested Citation

  • David Bradford, 2003. "Addressing the Transfer-Pricing Problem in an Origin-Basis X Tax," CESifo Working Paper Series 997, CESifo Group Munich.
  • Handle: RePEc:ces:ceswps:_997
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    References listed on IDEAS

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    1. David F. Bradford, 1998. "Transition to and Tax-Rate Flexibility in a Cash-Flow-Type Tax," NBER Chapters,in: Tax Policy and the Economy, Volume 12, pages 151-172 National Bureau of Economic Research, Inc.
    2. Auerbach, Alan J. & Bradford, David F., 2004. "Generalized cash-flow taxation," Journal of Public Economics, Elsevier, vol. 88(5), pages 957-980, April.
    3. Charles E. Mclure, 1987. "The Value Added Tax," Books, American Enterprise Institute, number 725195.
    4. Martin S. Feldstein & Paul R. Krugman, 1990. "International Trade Effects of Value-Added Taxation," NBER Chapters,in: Taxation in the Global Economy, pages 263-282 National Bureau of Economic Research, Inc.
    5. Boadway, Robin & Bruce, Neil, 1984. "A general proposition on the design of a neutral business tax," Journal of Public Economics, Elsevier, vol. 24(2), pages 231-239, July.
    6. Gordon, Roger H. & Hines, James Jr, 2002. "International taxation," Handbook of Public Economics,in: A. J. Auerbach & M. Feldstein (ed.), Handbook of Public Economics, edition 1, volume 4, chapter 28, pages 1935-1995 Elsevier.
    7. David Bradford, "undated". "Consumption Taxes: Some Fundamental Transition Issues," EPRU Working Paper Series 95-15, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics.
    8. Feldstein, Martin, 1976. "On the theory of tax reform," Journal of Public Economics, Elsevier, vol. 6(1-2), pages 77-104.
    9. Robert E. Hall, 1996. "The Effects of Tax Reform on Prices and Asset Values," NBER Chapters,in: Tax Policy and the Economy, Volume 10, pages 71-88 National Bureau of Economic Research, Inc.
    10. Zodrow, George R., 1995. "Taxation, uncertainty and the choice of a consumption tax base," Journal of Public Economics, Elsevier, vol. 58(2), pages 257-265, October.
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    JEL classification:

    • H20 - Public Economics - - Taxation, Subsidies, and Revenue - - - General
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies

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