To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the arm's length principle in corporate taxation and use comparable market prices to `correctly' assess the value of intracompany trade and royalty income of multinationals. We develop a model of heterogeneous firms subject to financing frictions and offshoring of intermediate inputs. We find that arm's length prices systematically differ from independent party prices. Application of the principle thus distorts multinational activity by reducing debt capacity and investment of foreign affiliates, and by distorting organizational choice between direct investment and outsourcing. Although it raises tax revenue and welfare in the headquarter country,...
Transfer pricing is relevant in three different contexts: From a managerial perspective, intra-firm ...
The profit split method in its current form is a relatively new part of the OECD transfer pricing gu...
This article examines the current transfer pricing regime to consider whether it is a sound model to...
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...
Profit shifting due to manipulation of transfer prices erodes the corporate tax base in high tax cou...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
This paper analyzes incentives of a multinational enterprise to manipulate an internal transfer pric...
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...
When multinational enterprises (MNEs) separate the geographical location of affiliates, they can shi...
The Arm’s Length Principle (ALP) has been broadly adopted by OECD countries to avoid the use of firm...
The Arm’s Length Principle (ALP) has been broadly adopted by OECD countries to avoid the use of firm...
Numerous (high-tax) countries presume that multinational ¯rms use their transfer-pricing policies to...
Transfer pricing is relevant in three different contexts: From a managerial perspective, intra-firm ...
The profit split method in its current form is a relatively new part of the OECD transfer pricing gu...
This article examines the current transfer pricing regime to consider whether it is a sound model to...
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...
Profit shifting due to manipulation of transfer prices erodes the corporate tax base in high tax cou...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
This paper analyzes incentives of a multinational enterprise to manipulate an internal transfer pric...
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...
When multinational enterprises (MNEs) separate the geographical location of affiliates, they can shi...
The Arm’s Length Principle (ALP) has been broadly adopted by OECD countries to avoid the use of firm...
The Arm’s Length Principle (ALP) has been broadly adopted by OECD countries to avoid the use of firm...
Numerous (high-tax) countries presume that multinational ¯rms use their transfer-pricing policies to...
Transfer pricing is relevant in three different contexts: From a managerial perspective, intra-firm ...
The profit split method in its current form is a relatively new part of the OECD transfer pricing gu...
This article examines the current transfer pricing regime to consider whether it is a sound model to...