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External Variables Affecting the Transfer Pricing Decisions: Arm’s Length Basis and Transfer Pricing

Author

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  • Bukhari, Muhammad Zaman
  • Ali, Amjad
  • Audi, Marc

Abstract

Transfer pricing estimations play a crucial role in transactions involving multinational enterprises, and the decisions regarding transfer pricing may be affected by a range of influential factors. This research investigates selected external determinants that impact transfer pricing choices made by multinational enterprises across a sample comprising 95 countries. Panel data covering the years from 2014 to 2023 has been employed for empirical analysis, and using panel data regression techniques, the study assesses the influence of several variables, including effective tax rates, the level of economic development, the extent of trade openness, and the quality of regulatory institutions, which shape the strategies of multinational enterprises concerning profit shifting. The findings indicate that lower levels of taxation, weaker enforcement of legal standards, and greater trade openness contribute to a higher probability of manipulative transfer pricing behavior. The research concludes that practices related to base erosion and profit shifting can be curtailed by improving the strength of legal enforcement mechanisms.

Suggested Citation

  • Bukhari, Muhammad Zaman & Ali, Amjad & Audi, Marc, 2025. "External Variables Affecting the Transfer Pricing Decisions: Arm’s Length Basis and Transfer Pricing," MPRA Paper 127320, University Library of Munich, Germany.
    • Handle: RePEc:pra:mprapa:127320
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    References listed on IDEAS

    as
    1. Martin Hearson, 2018. "Transnational expertise and the expansion of the international tax regime: imposing ‘acceptable’ standards," Review of International Political Economy, Taylor & Francis Journals, vol. 25(5), pages 647-671, September.
    2. Michael P. Devereux & John Vella, 2014. "Are We Heading towards a Corporate Tax System Fit for the 21-super-st Century?," Fiscal Studies, Institute for Fiscal Studies, vol. 35, pages 449-475, December.
    3. Clausing, Kimberly A., 2003. "Tax-motivated transfer pricing and US intrafirm trade prices," Journal of Public Economics, Elsevier, vol. 87(9-10), pages 2207-2223, September.
    4. Pedroni, Peter, 2004. "Panel Cointegration: Asymptotic And Finite Sample Properties Of Pooled Time Series Tests With An Application To The Ppp Hypothesis," Econometric Theory, Cambridge University Press, vol. 20(3), pages 597-625, June.
    5. Khalil Ahmad & Amjad Ali & Michael Yang, 2022. "The Effect Of Trade Liberalization On Expenditure Structure Of Pakistan," Bulletin of Business and Economics (BBE), Research Foundation for Humanity (RFH), vol. 11(1), pages 73-84, March.
    6. Gabriel Zucman, 2014. "Taxing across Borders: Tracking Personal Wealth and Corporate Profits," Journal of Economic Perspectives, American Economic Association, vol. 28(4), pages 121-148, Fall.
    7. Marc Audi & Marc Poulin & Amjad Ali, 2024. "Determinants of Business Freedom in Developing Countries: The Role of Institutional Development and Policy Mix," International Journal of Economics and Financial Issues, Econjournals, vol. 14(4), pages 188-199, July.
    8. Grubert, Harry & Mutti, John, 1991. "Taxes, Tariffs and Transfer Pricing in Multinational Corporate Decision Making," The Review of Economics and Statistics, MIT Press, vol. 73(2), pages 285-293, May.
    9. Kao, Chihwa, 1999. "Spurious regression and residual-based tests for cointegration in panel data," Journal of Econometrics, Elsevier, vol. 90(1), pages 1-44, May.
    10. Im, Kyung So & Pesaran, M. Hashem & Shin, Yongcheol, 2003. "Testing for unit roots in heterogeneous panels," Journal of Econometrics, Elsevier, vol. 115(1), pages 53-74, July.
    11. Dhammika Dharmapala, 2014. "What Do We Know about Base Erosion and Profit Shifting? A Review of the Empirical Literature," Fiscal Studies, Institute for Fiscal Studies, vol. 35, pages 421-448, December.
    12. Peter Pedroni, 1999. "Critical Values for Cointegration Tests in Heterogeneous Panels with Multiple Regressors," Oxford Bulletin of Economics and Statistics, Department of Economics, University of Oxford, vol. 61(S1), pages 653-670, November.
    13. repec:bla:obuest:v:61:y:1999:i:0:p:631-52 is not listed on IDEAS
    14. Johannesen, Niels, 2014. "Tax avoidance with cross-border hybrid instruments," Journal of Public Economics, Elsevier, vol. 112(C), pages 40-52.
    15. Badi H. Baltagi, 2021. "Econometric Analysis of Panel Data," Springer Texts in Business and Economics, Springer, edition 6, number 978-3-030-53953-5, January.
    16. Dharmapala, Dhammika & Riedel, Nadine, 2013. "Earnings shocks and tax-motivated income-shifting: Evidence from European multinationals," Journal of Public Economics, Elsevier, vol. 97(C), pages 95-107.
    17. 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.
    18. Griffith, Rachel & Miller, Helen & O'Connell, Martin, 2014. "Ownership of intellectual property and corporate taxation," Journal of Public Economics, Elsevier, vol. 112(C), pages 12-23.
    19. Hearson, Martin, 2018. "Transnational expertise and the expansion of the international tax regime: imposing ‘acceptable’ standards," LSE Research Online Documents on Economics 88351, London School of Economics and Political Science, LSE Library.
    20. Bartelsman, Eric J. & Beetsma, Roel M. W. J., 2003. "Why pay more? Corporate tax avoidance through transfer pricing in OECD countries," Journal of Public Economics, Elsevier, vol. 87(9-10), pages 2225-2252, September.
    21. Michael P. Devereux & John Vella, 2015. "Are We Heading towards a Corporate Tax System Fit for the 21st Century?," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(04), pages 03-07, January.
    22. Dhammika Dharmapala, 2008. "What problems and opportunities are created by tax havens?," Oxford Review of Economic Policy, Oxford University Press and Oxford Review of Economic Policy Limited, vol. 24(4), pages 661-679, winter.
    23. G. S. Maddala & Shaowen Wu, 1999. "A Comparative Study of Unit Root Tests with Panel Data and a New Simple Test," Oxford Bulletin of Economics and Statistics, Department of Economics, University of Oxford, vol. 61(S1), pages 631-652, November.
    24. repec:bla:obuest:v:61:y:1999:i:0:p:653-70 is not listed on IDEAS
    25. Levin, Andrew & Lin, Chien-Fu & James Chu, Chia-Shang, 2002. "Unit root tests in panel data: asymptotic and finite-sample properties," Journal of Econometrics, Elsevier, vol. 108(1), pages 1-24, May.
    26. Javier Garcia-Bernardo & Jan Fichtner & Eelke M. Heemskerk & Frank W. Takes, 2017. "Uncovering Offshore Financial Centers: Conduits and Sinks in the Global Corporate Ownership Network," Papers 1703.03016, arXiv.org, revised May 2017.
    27. Sebastian Beer & Ruud de Mooij & Li Liu, 2020. "International Corporate Tax Avoidance: A Review Of The Channels, Magnitudes, And Blind Spots," Journal of Economic Surveys, Wiley Blackwell, vol. 34(3), pages 660-688, July.
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    Cited by:

    1. Sattar, Sarmad & Alvi, Aramish Altaf & Audi, Marc, 2025. "Economic, Social, and Institutional Drivers of FDI: A Comparative Study of Developed and Developing Economies," MPRA Paper 127562, University Library of Munich, Germany.

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    JEL classification:

    • H2 - Public Economics - - Taxation, Subsidies, and Revenue
    • H3 - Public Economics - - Fiscal Policies and Behavior of Economic Agents

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