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Transfer Pricing and Debt Shifting in Multinationals

Author

Listed:
  • Schindler, Dirk

    (Dept. of Accounting, Auditing and Law, Norwegian School of Economics)

  • Schjelderup, Guttorm

    (Dept. of Business and Management Science, Norwegian School of Economics)

Abstract

There is a growing concern that governments lose substantial corporate tax revenue due to transfer pricing and debt shifting strategies. Existing literature studies debt shifting and transfer pricing separately. In practice, however, the choice of debt-to-asset ratios in affiliates and the transfer price of internal debt are interrelated management decisions that are also mutually affected by government regulation. This paper models these strategies as intertwined. We find that the tax sensitivity of the corporate tax base depends on whether debt shifting and transfer pricing are cost complements or substitutes. A second result is that stricter regulation of debt shifting and transfer pricing may have the effect of fostering such activities.

Suggested Citation

  • Schindler, Dirk & Schjelderup, Guttorm, 2014. "Transfer Pricing and Debt Shifting in Multinationals," Discussion Papers 2014/22, Norwegian School of Economics, Department of Business and Management Science.
    • Handle: RePEc:hhs:nhhfms:2014_022
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    File URL: http://hdl.handle.net/11250/217628
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    Cited by:

    1. Thiess Buettner & Michael Overesch & Georg Wamser, 2018. "Anti profit-shifting rules and foreign direct investment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 25(3), pages 553-580, June.
    2. Martin Simmler, 2014. "Do multinational firms invest more? On the impact of internal debt financing on capital accumulation," Working Papers 1424, Oxford University Centre for Business Taxation.
    3. Ruf Martin & Schindler Dirk, 2015. "Debt Shifting and Thin-Capitalization Rules – German Experience and Alternative Approaches," Nordic Tax Journal, Sciendo, vol. 2015(1), pages 17-33, September.
    4. Schindler, Dirk & Schjelderup, Guttorm, 2012. "Debt shifting and ownership structure," European Economic Review, Elsevier, vol. 56(4), pages 635-647.
    5. Alex A. T. Rathke, 2023. "Profit shifting under the arm's length principle," Papers 2309.13449, arXiv.org.
    6. Kayis-Kumar, Ann, 2015. "Thin capitalisation rules: A second-best solution to the cross-border debt bias?," MPRA Paper 72031, University Library of Munich, Germany.
    7. Egger, Peter H. & Strecker, Nora M. & Zoller-Rydzek, Benedikt, 2020. "Estimating bargaining-related tax advantages of multinational firms," Journal of International Economics, Elsevier, vol. 122(C).
    8. Hansson, Åsa & Olofsdotter, Karin & Thede, Susanna, 2016. "Do Multinationals Pay Less in Taxes than Domestic Firms? Evidence from the Swedish Manufacturing Sector," Working Papers 2016:17, Lund University, Department of Economics.
    9. Mardan, Mohammed, 2017. "Why countries differ in thin capitalization rules: The role of financial development," European Economic Review, Elsevier, vol. 91(C), pages 1-14.

    More about this item

    Keywords

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    JEL classification:

    • D21 - Microeconomics - - Production and Organizations - - - Firm Behavior: Theory
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies

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