The goals of transfer pricing are to assign a monetary value to a transfer and to minimize the taxes paid by a company as whole. However, because a single company can now have operations literally around the world, transfer pricing has become a very complicated, costly, and lucrative business...

This paper examines transfer pricing in general. First, three different approaches to transfer pricing options and their advantages and disadvantages are investigated. Based on the analysis, it is difficult to make recommendations on the best transfer pricing methods. Next, the international...

The objective of this paper is to analyze the procedures used by multinational enterprises to distribute the income generated by its foreign subsidiaries, and how they allocate the taxes paid on this income through the fiscal jurisdiction in which they operate, from the institution based view....

Successful IRS enforcement of corporate transfer pricing regulations is by all measures at an all-time low, and profit shifting from transfer pricing appears to be near an all-time high, costing the U.S. federal and state treasuries as much $140 billion dollars or more per annum in recent years,...

Finding common ground between corporate tax compliance and enforcement appears difficult and expensive, judging by the current inventory of almost $200 billion in proposed IRS transfer pricing tax adjustments, and projections of as much as $100 billion or more in annual U.S. federal corporate...

This paper provides direct evidence of profit shifting to low tax jurisdictions by multinational companies through transfer prices. Using detailed firm level export and import data by origin/destination and product for France, I show that the price wedge between arm's length and related party...

Using unique transaction-level microdata, this paper documents profit-shifting behavior by U.S. multinational firms via the strategic transfer pricing of intra-firm trade. A simple model reveals how differences in tax rates, both the corporate tax rates across countries and the dividend...

This paper examines how prices set by multinational firms vary across arm's-length and related party customers. Comparing prices within firms, products, destination countries, modes of transport and month, we find that the prices U.S. exporters set for their arm's-length customers are...

This paper analyzes the transfer pricing of multinational firms. We propose a simple framework in which intra-firm prices may systematically deviate from arm's length prices for two motives: i) pricing to market, and ii) tax avoidance. Multinational firms may decide not to avoid taxes if the...

What are the implications of the rapid growth in offshored business services for transfer pricing, the pricing of products traded between affiliated firms? We explore these implications through a case study of transnational corporations in the teleservices industry. Teleservices TNCs own foreign...