Tax planning with intangibles has become one of the most popular and most vividly debated topics in international taxation. We incorporate various intellectual property (IP) tax planning models into forward-looking measures of effective tax rates, namely the disposal of intangibles to low-tax...

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...

This paper examines the determinants and margins of profit shifting through transfer pricing. We develop a theory model, where transfer pricing patterns are governed by a generalized concealment cost function (CCF). Our empirical analysis draws on micro-level data about transaction-level...

We study the link between a country’s institutional quality in tax collection and its optimal corporate tax policies in a model of heterogeneous multinationals that can shift income using both debt and transfer prices. Countries with weak institutional quality can be made worse off adopting...

This paper models strategic taxation policy of home and host governments when a multinational enterprise sets transfer prices on globally joint inputs such as research and development. Tax credit and deduction allowances, as well as no taxation of foreign-earned profits, result in identical...

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...

The main focus of this paper is on the international transfer pricing issues encountered by multinational enterprises (MNE) and the countries they do business in. This paper explores how the conflicting interests of MNEs and the countries they do business in affects each party's bottom line, tax...

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...

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...