Automobile dealership contracts, the management practice of category management, and transfer pricing practices by multinationals can exhibit a property we refer to as partial delegation. In a bargaining problem between an informed party and an uninformed party, partial delegation involves the...

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...

This paper derives welfare equivalence of double taxation rules in a tax competition model with discriminatory home taxes and the ability to finance subsidiary operations with host country capital. For a more general model, we provide sufficient conditions on the number of host sectors and...

The view that the transfer pricing problem vanishes under universal destination-based cash flow taxation (DBCFT) is based on how firms behave in perfectly competitive markets. We show that the neutralizing effect DBCFT has on transfer price incentives fails once multinational firms are...

While some countries coordinate their tax policies for multinationals with their commercial trade policies, the practice is not universal. Many countries, including the United States, formulate tax policies solely to mitigate tax avoidance practices like strategic transfer pricing. In this...

In this paper we use a model of tax competition to study the role of information sharing in common agency problems. Two national governments are assumed to compete in tax schedules for the revenues and output of a multinational firm in which only one of the governments is informed about the...

In 2002, the European Commission recommended that member countries use formula apportionment procedures to tax multinational companies. This departure from the standard separate accounting (transfer pricing) approach is an attempt to reduce the costs and distortions associated with auditing...