Profit shifting due to manipulation of transfer prices erodes the corporate tax base in high tax countries. To protect tax revenues, governments typically apply the arm’s length principle to ‘correctly ’ assess the value of intracompany trade and royalty income based on observed market transactions such as in comparable outsourcing relationships. We develop a model of heterogeneous firms which are subject to agency costs in external financing and choose between outsourcing and foreign direct investment. We show that the application of the arm’s length principle distorts financing and investment of multinational firms, the choice between outsourcing and direct investment, and leads to a reduction of world welfare
This paper analyzes the optimal level of transfer pricing manipulation when the expected tax penalty...
"Tax-motivated transfer pricing has attracted world attention owing to the existence of low-tax jur...
The OECD Base Erosion Profit Shifting (BEPS) Initiative as well as the current fairness oriented pub...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
This article analyzes profit taxation according to the arm's length principle in a new model where h...
This article analyzes profit taxation according to the arm's length principle in a new model where h...
This paper analyzes incentives of a multinational enterprise to manipulate an internal transfer pric...
The profit split method in its current form is a relatively new part of the OECD transfer pricing gu...
When multinational enterprises (MNEs) separate the geographical location of affiliates, they can shi...
Multinational enterprises (MNEs) operating by way of wholly owned subsidiaries are responsible for a...
The arm’s length principle has been the allocation rule for income between associated enterprises fo...
This paper analyzes the optimal level of transfer pricing manipulation when the expected tax penalty...
"Tax-motivated transfer pricing has attracted world attention owing to the existence of low-tax jur...
The OECD Base Erosion Profit Shifting (BEPS) Initiative as well as the current fairness oriented pub...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
This article analyzes profit taxation according to the arm's length principle in a new model where h...
This article analyzes profit taxation according to the arm's length principle in a new model where h...
This paper analyzes incentives of a multinational enterprise to manipulate an internal transfer pric...
The profit split method in its current form is a relatively new part of the OECD transfer pricing gu...
When multinational enterprises (MNEs) separate the geographical location of affiliates, they can shi...
Multinational enterprises (MNEs) operating by way of wholly owned subsidiaries are responsible for a...
The arm’s length principle has been the allocation rule for income between associated enterprises fo...
This paper analyzes the optimal level of transfer pricing manipulation when the expected tax penalty...
"Tax-motivated transfer pricing has attracted world attention owing to the existence of low-tax jur...
The OECD Base Erosion Profit Shifting (BEPS) Initiative as well as the current fairness oriented pub...