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The Effects Of Transfer Pricing On The Performance Of Us Manufacturing Industries From 1972 1982 And Its Implications For Vertically Integrated Firms
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Book Synopsis The Effects of Transfer Pricing on the Performance of U.S. Manufacturing Industries from 1972-1982 and Its Implications for Vertically Integrated Firms by : Rory S. Cates
Download or read book The Effects of Transfer Pricing on the Performance of U.S. Manufacturing Industries from 1972-1982 and Its Implications for Vertically Integrated Firms written by Rory S. Cates and published by . This book was released on 1986 with total page 148 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Transfer Pricing and Valuation in Corporate Taxation by : Elizabeth King
Download or read book Transfer Pricing and Valuation in Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2007-05-08 with total page 294 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer Pricing and Valuation in Corporate Taxation analyzes the disparities between both federal statutes and regulations, and r- ulations and administrative practice, in a highly controversial area of corporate tax policy: intra-company transfer pricing for tax p- poses. It addresses issues that often mean millions of dollars to in- vidual corporations, and a significant fraction of the federal gove- ment’s revenue base. These disparities between law, regulations, and administrative practice are concerning on a number of grounds. First, they - pose considerable economic costs by inducing corporations to engage in a variety of “rent-seeking” activities designed to reduce their - pected tax liabilities, and by requiring the IRS to devote still more to enforcement efforts that are very often futile. Second, they are in- ; herently undemocratic. Administrative practice is currently ad hoc by relying on dispute resolution procedures that can and do yield very different settlements on disputed tax issues from one case to another, the IRS often ends up treating similarly situated cor- rations very differently. Moreover, to the extent that the disp- ity between statute and implementation reflects the IRS’s failure to carry out Congress’ will, the laws passed by duly elected officials are effectively being superseded by administrative procedure, developed incrementally by individuals who are not answerable to an electorate.
Book Synopsis At A Cost: the Real Effects of Transfer Pricing Regulations by : Ruud A. de Mooij
Download or read book At A Cost: the Real Effects of Transfer Pricing Regulations written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2018-03-23 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt: Unilateral adoption of transfer pricing regulations may have a negative impact on real investment by multinational corporations (MNCs). This paper uses a quasi-experimental research design, exploiting unique panel data on domestic and multinational companies in 27 countries during 2006-2014, to find that MNC affiliates reduce their investment by over 11 percent following the introduction of transfer pricing regulations. There is no significant reduction in total investment by the MNC group, suggesting that these investments are most likely shifted to affiliates in other countries. The impact of transfer pricing regulations corresponds to an increase in the ``TPR-adjusted'' corporate tax rate by almost one quarter.
Book Synopsis At A Cost: the Real Effects of Transfer Pricing Regulations by : Ruud A. de Mooij
Download or read book At A Cost: the Real Effects of Transfer Pricing Regulations written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2018-03-23 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt: Unilateral adoption of transfer pricing regulations may have a negative impact on real investment by multinational corporations (MNCs). This paper uses a quasi-experimental research design, exploiting unique panel data on domestic and multinational companies in 27 countries during 2006-2014, to find that MNC affiliates reduce their investment by over 11 percent following the introduction of transfer pricing regulations. There is no significant reduction in total investment by the MNC group, suggesting that these investments are most likely shifted to affiliates in other countries. The impact of transfer pricing regulations corresponds to an increase in the ``TPR-adjusted'' corporate tax rate by almost one quarter.
Book Synopsis Transfer Pricing in Vertically Integrated Industries by : Thomas A. Gresik
Download or read book Transfer Pricing in Vertically Integrated Industries written by Thomas A. Gresik and published by . This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax officials judge whether a multinational's transfer price is consistent with the arm's-length standard, the price at which two independent firms would carry out a similar transaction, by using data from comparable but independent transactions. In vertically integrated industries, the only source of comparable data may be from controlled (non-independent) transactions. Conventional wisdom asserts that standard arm's-length methods cannot perform well in such markets because the comparability rules encourage the integrated firms to collude tacitly on transfer prices in a way that amplifies tax-differential incentives. In this paper, we show that strategic linkages between vertically integrated firms operating in the same final good market moderate, and can possibly reverse, tax-differential incentives if the correct comparison method is used.The Cost-Plus method turns out to be the most effective in limiting the equilibrium amount of profit-shifting out of the high-tax country and it yields the highest tax revenues for the high-tax country. These benefits are shown to strengthen when the firms have private cost information.
Book Synopsis Transfer Pricing and Corporate Taxation by : Elizabeth King
Download or read book Transfer Pricing and Corporate Taxation written by Elizabeth King and published by Springer Science & Business Media. This book was released on 2008-10-11 with total page 199 pages. Available in PDF, EPUB and Kindle. Book excerpt: National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.
Book Synopsis Multinationals and Transfer Pricing by : Alan M. Rugman
Download or read book Multinationals and Transfer Pricing written by Alan M. Rugman and published by Routledge. This book was released on 2017-02-03 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: One of the reasons for the success of multinational enterprises in their ability to create in their supranational organisations "internal markets" which eliminate the imperfections of external world markets caused by tariffs on trade, restrictions on the flow of capital, information costs and so on. The method multinationals use to create and sustain internal markets is transfer pricing. Multinationals use to their advantage the difference between nominal accounting and real transfers from their head offices to a subsidiary in different countries to overcome transaction costs and restrictions on trade and capital flows. This book, first published in 1985, examines these and other aspects of multinationals’ use of transfer pricing. It puts forward original thinking and research findings by leading experts in this area. Empirical results are related to the activities of multinationals in less developed countries. This volume covers the economic theories of transfer pricing, accounting and fiscal practices and implications for government policies and regulations, and will be of interest to students of economics and business studies.
Book Synopsis Comprehensive Dissertation Index: Business & economics, A-K by :
Download or read book Comprehensive Dissertation Index: Business & economics, A-K written by and published by . This book was released on 1984 with total page 808 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Current Trends and Corporate Cases in Transfer Pricing by : Roger Y. Tang
Download or read book Current Trends and Corporate Cases in Transfer Pricing written by Roger Y. Tang and published by Praeger. This book was released on 2002-04-30 with total page 208 pages. Available in PDF, EPUB and Kindle. Book excerpt: Global changes in business and tax environments are having profound impact on the volume and direction of intrafirm trade and transfer pricing strategies. Tang reports on the findings of a survey of 95 Fortune 1000 companies, sponsored by the Institute of Management Accountants, and provides highly relevant information not easily found on how companies are reacting to this new business environment. He covers corporate financial goals and strategies and divisonal performance measurements systems, among other topics, and gives highly detailed case studies based on reports from five major respondents to his survey: Whirlpool, Dow Chemical, Guidant Corporation, Masco, and Eaton. Tang's book is essential, up-to-date reading for upper level students, researchers, analysts, and corporate executives in multinational firms worldwide. Tang starts with a presentation of the major changes in the global business environment and explains their impact on intrafirm trade and transfer pricing. In Chapter 2 he reports results of his questionnaire survey, and in Chapters 3 to 7 examines up close the details revealed in his five corporate case studies. He compares these corporations in Chapter 8, focusing on corporate strategies and financial goals, transfer pricing and performance evaluation practices, and concommitant tax planning strategies. He then relates his case study research to other major findings derived from his questionnaire survey, and ends the book with a general, summarizing, analytical conclusion.
Book Synopsis The Impact of Transfer Pricing on Intrafirm Trade by : Kimberly A. Clausing
Download or read book The Impact of Transfer Pricing on Intrafirm Trade written by Kimberly A. Clausing and published by . This book was released on 1998 with total page 19 pages. Available in PDF, EPUB and Kindle. Book excerpt: Using data on the operations of U.S. parent firms and their foreign affiliates between 1982 and 1994, this paper examines the extent to which tax minimizing behavior influences intrafirm trade. The results indicate that taxes have a substantial influence on intrafirm trade flows between U.S. parent firms and their affiliates abroad; the United States has less favorable intrafirm trade balances with low tax countries. This result is anticipated if U.S. sales to affiliates in low tax countries are underpriced and U.S. purchases from affiliates in high tax countries are overpriced. Taxes are also shown to have an influence on intrafirm trade flows between different foreign affiliates of U.S. firms
Book Synopsis The Transfer Pricing Problem by : Robert G. Eccles
Download or read book The Transfer Pricing Problem written by Robert G. Eccles and published by Free Press. This book was released on 1985 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt: Author explores the transfer pricing policies. On the beginning, he identifies the elements of administrative process that are crucial for managing the transfer pricing in corporate practice. Furthermore, he examines the management challenges of the most common transfer pricing policies. Finally, he presents general framework for strategy implementation that is designed to help managers to analyse their own company transfer pricing practices.
Book Synopsis Market Structure and Industrial Performance by : Claudio R. Frischtak
Download or read book Market Structure and Industrial Performance written by Claudio R. Frischtak and published by Taylor & Francis. This book was released on 1994 with total page 398 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Optimal Transfer Pricing in a Vertically-Related and Imperfectly Competitive Market by : Winston W. Chang
Download or read book Optimal Transfer Pricing in a Vertically-Related and Imperfectly Competitive Market written by Winston W. Chang and published by . This book was released on 2016 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: The objective of this paper is to find the significant factors that crucially affect a firm's optimal transfer pricing policy. To achieve such a goal, it suffices to examine three minimalist vertical models: the first one contains a vertically integrated monopoly in both input and output markets, the second one consists of a vertically integrated firm that monopolizes an intermediate input for its own and rival's downstream divisions, and the third one comprises two vertically integrated firms competing in a final goods market. Four modes of competition are considered: Cournot, Bertrand, Stackelberg quantity and Stackelberg price. The paper shows that the optimal transfer pricing policy depends on four specifications: the vertical structure, the production technology, the demand characteristics and the competition mode. It finds numerous patterns on optimal transfer pricing: for example, under the same demand structure and competition mode, the two vertical models can yield diametrically opposite transfer pricing strategies; within a given vertical model, different competition modes may yield the same or different optimal strategies; and within a given competition mode, the four possible pairings of ordinary substitutes/complements on the demand side and strategic substitutes/complements on the firm side can also produce quite different results. In addition, the paper illustrates how the optimal transfer pricing policy is affected when the additional factors of income tax and tariff distortions are considered. With all the significant factors affecting the optimal transfer pricing delineated, the paper has laid a foundation for further studies in transfer pricing under more general structures. An important implication of our results is that the optimal transfer pricing policy may not be simply determined by the common practice of shifting profits from high- to low-tax jurisdictions.
Book Synopsis Transfer Pricing in the Multinational Firm (Classic Reprint) by : James S. Shulman
Download or read book Transfer Pricing in the Multinational Firm (Classic Reprint) written by James S. Shulman and published by Forgotten Books. This book was released on 2017-09-12 with total page 46 pages. Available in PDF, EPUB and Kindle. Book excerpt: Excerpt from Transfer Pricing in the Multinational Firm The spread of decentralized corporate operations has been accompanied by widespread utilization Of the profit center concept to measure, evaluate, and motivate divisional management. As the implications of the profit center idea have been recognized, the need has arisen for rational systems to price intra-company transfers of goods at varying stages of production. The aim, in general, has been to devise methods which would satisfy' the goals of divisional managers to earn adequate profit for their divisions, while simultaneously furthering corporate profit goals. In single country Operations, the system is meant to function for this purpose and to provide a foundation for a properly Operating control system. But when a company operates across national borders and exports its practice of decentralized management, with all the accompanying apparatus, new complicating dimensions are added. In international business, there are Opportunities to maximize profits which may override the significance of a control system and the transfer pricing mechanism. Likewise, this environment contains threats to international firms, often unforeseen and, even when perceived, seldom factored into control systems. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.
Download or read book Transfer Pricing written by Marc M. Levey and published by . This book was released on 2013 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is one of the most significant tax issues for corporations having international operations. It attracts the scrutiny of tax authorities worldwide and continues to draw attention of more and more countries' tax legislatures. Because of the heavy impact of income allocations on the bottom line of a corporation's business, especially potentially forced ones, international tax and business professionals need to be very careful about their tax planning and compliance efforts in order to meet the established transfer pricing standards. Transfer Pricing: Rules, Compliance and Controversy offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Throughout the book, the authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures.
Book Synopsis Intrafirm Trade and Global Transfer Pricing Regulations by : Roger Y. W. Tang
Download or read book Intrafirm Trade and Global Transfer Pricing Regulations written by Roger Y. W. Tang and published by Praeger. This book was released on 1997-07-16 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is the most important issue in international taxation today, but transfer pricing regulations for the United States and its major trading partners have changed significantly over the past decade. Professor Tang explains these changes and their impact on trade among multinational companies. In doing so he covers not only changes in U.S. regulations and their effects on multinational companies, but also the changes that have taken place in Canada, Mexico, China, Japan, the United Kingdom, Germany, France, the OECD, and elsewhere, and their impact on U.S. business. Also discussed in detail are the advance pricing agreements (APA) programs of the United States and Canada; a new paradigm for resolving a variety of issues that have arisen recently in intrafirm trade and transfer pricing; and, for business executives, an approach for managing a corporate transfer pricing system. The book is an essential reading for professionals and their colleagues in the academic community.
Book Synopsis Multinationals and World Trade (Routledge Revivals) by : Mark Casson
Download or read book Multinationals and World Trade (Routledge Revivals) written by Mark Casson and published by Routledge. This book was released on 2012-07-26 with total page 416 pages. Available in PDF, EPUB and Kindle. Book excerpt: First published in 1986, this work reports the results of the Leverhulme project on multinationals and intermediate product trade based at the University of Reading during the academic year 1982/3. Chapter 1 summaries the main results of this project. Part I focuses upon the theoretical component of world trade, dealing with both the theories of division of labour and vertical integration. Part II presents a number of specially-commissioned case studies relating to the project, concerning the motor industry, the bearing industry, the synthetic fibre industry, the tin industry, the copper industry, the banana industry and the shipping industry.
