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Multinational Transfer Pricing, Tax Arbitrage and the Arm's Length Principle

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  • CHONGWOO CHOE
  • CHARLES E. HYDE
Abstract
This paper studies the multinational firm's choice of transfer prices when the firm uses separate transfer prices for tax and managerial incentive purposes, and when there is penalty for non‐compliance with the arm's length principle. The optimal incentive transfer price is shown to be a weighted average of marginal cost and the optimal tax transfer price plus an adjustment by a fraction of the marginal penalty for non‐arm's length pricing. Insofar as the tax rates are different in different jurisdictions, the firm optimally trades off the benefits of tax arbitrage against the penalty for non‐arm's length pricing.

Suggested Citation

  • Chongwoo Choe & Charles E. Hyde, 2007. "Multinational Transfer Pricing, Tax Arbitrage and the Arm's Length Principle," The Economic Record, The Economic Society of Australia, vol. 83(263), pages 398-404, December.
    • Handle: RePEc:bla:ecorec:v:83:y:2007:i:263:p:398-404
    DOI: 10.1111/j.1475-4932.2007.00429.x
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    References listed on IDEAS

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    1. Charles E. Hyde & Chongwoo Choe, 2005. "Keeping Two Sets of Books: The Relationship Between Tax and Incentive Transfer Prices," Journal of Economics & Management Strategy, Wiley Blackwell, vol. 14(1), pages 165-186, March.
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    7. Kant, Chander, 1990. "Multinational firms and government revenues," Journal of Public Economics, Elsevier, vol. 42(2), pages 135-147, July.
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    Cited by:

    1. Kristian Behrens & Susana Peralt & Pierre M. Picard, 2014. "Transfer Pricing Rules, OECD Guidelines, and Market Distortions," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 16(4), pages 650-680, August.
    2. Diller, Markus & Lorenz, Johannes, 2017. "Do tax information exchange agreements curb transfer pricing-induced tax avoidance?," Passauer Diskussionspapiere, Betriebswirtschaftliche Reihe B-29-17, University of Passau, Faculty of Business and Economics.
    3. Diller, Markus & Lorenz, Johannes & Schneider, Georg & Sureth, Caren, 2021. "Is consistency the panacea? Inconsistent or consistent tax transfer prices with strategic taxpayer and tax authority behavior," arqus Discussion Papers in Quantitative Tax Research 264, arqus - Arbeitskreis Quantitative Steuerlehre.
    4. Choe, Chongwoo & Matsushima, Noriaki, 2013. "The arm's length principle and tacit collusion," International Journal of Industrial Organization, Elsevier, vol. 31(1), pages 119-130.
    5. Chongwoo Choe & Noriaki Matsushima, 2012. "The Arm’s Length Principle and Tacit Collusion," Monash Economics Working Papers 02-12, Monash University, Department of Economics.

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