Transfer Pricing: Roles and Regimes

Søren Bo Nielsen

Publikation: Bidrag til tidsskriftTidsskriftartikelForskningpeer review

Resumé

Against a background of rather mixed evidence about transfer pricing practices in multinational enterprises (MNEs) and varying attitudes on the part of tax authorities, this paper explores how multiple aims in transfer pricing can be pursued across four different transfer pricing regimes. A MNE has a production subsidiary in one country, from where it sells the produced good locally as well as to a sales subsidiary in a second country. The latter subsidiary is engaged in duopolistic competition with a local competitor. The MNE has two aims in setting
the transfer price: strategic delegation and tax minimization. We examine the extent to which the four transfer pricing regimes we set up allow the MNE to pursue these aims. While neither strategic delegation nor tax minimization will be eliminated, trade-offs are inevitable, albeit to varying degree.
OriginalsprogEngelsk
TidsskriftRevista de Economia Mundial
Vol/bind37
Sider (fra-til)103-122
ISSN1576-0162
StatusUdgivet - 2014

Emneord

  • Transfer prices
  • Strategic delegation
  • Tax manipulation
  • MNEs

Citer dette

Nielsen, Søren Bo. / Transfer Pricing : Roles and Regimes. I: Revista de Economia Mundial. 2014 ; Bind 37. s. 103-122.
@article{090a2d41a7144b4b94d715c729ecaa78,
title = "Transfer Pricing: Roles and Regimes",
abstract = "Against a background of rather mixed evidence about transfer pricing practices in multinational enterprises (MNEs) and varying attitudes on the part of tax authorities, this paper explores how multiple aims in transfer pricing can be pursued across four different transfer pricing regimes. A MNE has a production subsidiary in one country, from where it sells the produced good locally as well as to a sales subsidiary in a second country. The latter subsidiary is engaged in duopolistic competition with a local competitor. The MNE has two aims in settingthe transfer price: strategic delegation and tax minimization. We examine the extent to which the four transfer pricing regimes we set up allow the MNE to pursue these aims. While neither strategic delegation nor tax minimization will be eliminated, trade-offs are inevitable, albeit to varying degree.",
keywords = "Transfer prices, Strategic delegation, Tax manipulation, MNEs",
author = "Nielsen, {S{\o}ren Bo}",
year = "2014",
language = "English",
volume = "37",
pages = "103--122",
journal = "Revista de Economia Mundial",
issn = "1576-0162",
publisher = "Universidad de Huelva * Servicio de Publicaciones",

}

Nielsen, SB 2014, 'Transfer Pricing: Roles and Regimes', Revista de Economia Mundial, bind 37, s. 103-122.

Transfer Pricing : Roles and Regimes. / Nielsen, Søren Bo.

I: Revista de Economia Mundial, Bind 37, 2014, s. 103-122.

Publikation: Bidrag til tidsskriftTidsskriftartikelForskningpeer review

TY - JOUR

T1 - Transfer Pricing

T2 - Roles and Regimes

AU - Nielsen, Søren Bo

PY - 2014

Y1 - 2014

N2 - Against a background of rather mixed evidence about transfer pricing practices in multinational enterprises (MNEs) and varying attitudes on the part of tax authorities, this paper explores how multiple aims in transfer pricing can be pursued across four different transfer pricing regimes. A MNE has a production subsidiary in one country, from where it sells the produced good locally as well as to a sales subsidiary in a second country. The latter subsidiary is engaged in duopolistic competition with a local competitor. The MNE has two aims in settingthe transfer price: strategic delegation and tax minimization. We examine the extent to which the four transfer pricing regimes we set up allow the MNE to pursue these aims. While neither strategic delegation nor tax minimization will be eliminated, trade-offs are inevitable, albeit to varying degree.

AB - Against a background of rather mixed evidence about transfer pricing practices in multinational enterprises (MNEs) and varying attitudes on the part of tax authorities, this paper explores how multiple aims in transfer pricing can be pursued across four different transfer pricing regimes. A MNE has a production subsidiary in one country, from where it sells the produced good locally as well as to a sales subsidiary in a second country. The latter subsidiary is engaged in duopolistic competition with a local competitor. The MNE has two aims in settingthe transfer price: strategic delegation and tax minimization. We examine the extent to which the four transfer pricing regimes we set up allow the MNE to pursue these aims. While neither strategic delegation nor tax minimization will be eliminated, trade-offs are inevitable, albeit to varying degree.

KW - Transfer prices

KW - Strategic delegation

KW - Tax manipulation

KW - MNEs

M3 - Journal article

VL - 37

SP - 103

EP - 122

JO - Revista de Economia Mundial

JF - Revista de Economia Mundial

SN - 1576-0162

ER -