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A Critical Appraisal of Transfer Pricing by Multinational Corporations

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Purpose - This paper presents how Multinational Enterprises (MNEs) operate in different tax jurisdiction could decide on its transfer pricing strategy as the optimal solution to increase their global after tax income through transfer pricing and solve their related transfer pricing issues related to distribution cost, consumer, and wholesale vendor. It has been strategy issues for an MNEs to locate its tax basis of wholesale vendor and buyer in a jurisdiction where effective rather low Research design, data, and methodology - The collection of information and data for this research project gathered from various sources of secondary data. The findings of these relevant research topic article and journal were the main source of references for this research project Results - The achievement of management’s operational and financial objectives depends on transfer pricing policies availability that is consistent and supports both vendor, wholesaler, distributor and ensuring sufficient documentation and data is available to support the application and arriving at the arm length. Conclusions - The study concluded with an emphasis on the importance of web-designed information about international taxation rules and transfer pricing policy and pricing agreement among wholesale vendor and whole buyer around the world.

Abstract

Purpose - This paper presents how Multinational Enterprises (MNEs) operate in different tax jurisdiction could decide on its transfer pricing strategy as the optimal solution to increase their global after tax income through transfer pricing and solve their related transfer pricing issues related to distribution cost, consumer, and wholesale vendor. It has been strategy issues for an MNEs to locate its tax basis of wholesale vendor and buyer in a jurisdiction where effective rather low Research design, data, and methodology - The collection of information and data for this research project gathered from various sources of secondary data. The findings of these relevant research topic article and journal were the main source of references for this research project Results - The achievement of management’s operational and financial objectives depends on transfer pricing policies availability that is consistent and supports both vendor, wholesaler, distributor and ensuring sufficient documentation and data is available to support the application and arriving at the arm length. Conclusions - The study concluded with an emphasis on the importance of web-designed information about international taxation rules and transfer pricing policy and pricing agreement among wholesale vendor and whole buyer around the world.

참고문헌 (41)

  1. Azémar, C., "Multinational firms’ heterogeneity in tax responsiveness : The role of transfer pricing", World Economy, 32(9), pp.1291~1318 (2009)
  2. Beetsma, R. M. W. J., "Why Pay More? Tax Avoidance through Transfer Pricing in the OECD", Journal of Public Economics, 87, pp.2225~2252 (2003)
  3. Bernard, A. B., "Transfer pricing by US-based multinational firms(No. w12493)", National Bureau of Economic Research, ~ (2006)
  4. Borkowski, S. C., "The transfer pricing concerns of developed and developing countries", The International Journal of Accounting, 32(3), pp.321~336 (1997)
  5. Carter, W. K., "The Problems of Transfer Pricing : When you have facilities in more than one tax jurisdiction", Journal of Accountancy, 186(1), pp.37~40 (1998)
  6. Clausing, K. A., "The impact of transfer pricing on intrafirm trade. In International taxation and multinational activity", pp.173~200 (2000), University of Chicago Press
  7. Clausing, K. A., "Tax-motivated transfer pricing and US intrafirm trade prices", Journal of Public Economics, 87(9), pp.2207~2223 (2003)
  8. Cools, M., "Tax-compliant transfer pricing and responsibility accounting", Journal of Management Accounting Research, 21(1), pp.151~178 (2009)
  9. Cools, M., "Management control in the transfer pricing tax compliant multinational enterprise. Accounting", Organizations and Society, 33(6), pp.603~628 (2008)
  10. Cravens, K. S., "Examining the role of transfer pricing as a strategy for multinational firms", International Business Review, 6(2), pp.127~145 (1997)
  11. Dawson, P. C., "International Transfer Pricing for Goods and Intangible Asset Licenses in a Decentralized Multinational Corporation", Review and Extensions (2009)
  12. Dean, M., "International transfer pricing issues and strategies for the global firm", Internal Auditing, 23(1), pp.12~19 (2008)
  13. "Global Transfer pricing Solutions: Trasfer Pricing Architect" (2001)[URL]
  14. Eden, L., "Not at Arm's Length : A Guide to Transfer Pricing Resources", Journal of Business & Finance Librarianship, 6(4), pp.3~22 (2001)
  15. Gérard, M., "Optimal transfer pricing under acceptance uncertainty and risk aversion", Arpege, Fucam, mimeo, 28~ (2001)
  16. Göx, R. F., "Handbooks of Management Accounting Research, 2", pp.673~695 (2006)
  17. "Michael Heimert"[URL]
  18. Hines Jr, J. R., "The transfer pricing problem : where the profits are(No. w3538)", National Bureau of Economic Research, ~ (1990)
  19. Klassen, K. J., "Transfer pricing : Strategies, practices, and tax minimization", Contemporary Accounting Research, 31(4), pp.1103~1133 (2016)
  20. Lancioni, R., "Pricing issues in industrial marketing", Industrial Marketing Management, 34(2), pp.111~114 (2005)
  21. "Lehman brown" (2002)[URL]
  22. "Lehman brown" (2002)[URL]
  23. Li, D., "Internal and external factors on firms’ transfer pricing decisions: insights from organization studies", ~ (2007)
  24. Liu, G., "Strategic transfer pricing in a marketing–operations interface with quality level and advertising dependent goodwill", Omega, 56, pp.1~15 (2015)
  25. Marques, M., "Is transfer pricing strictness deterring profit shifting within multinationals? Empirical evidence from Europe", Accounting and Business Research, pp.1~28 (2016)
  26. "Practical solutions for Intercompany Pricing" (2002)[URL]
  27. Neighbour, J., "Transfer pricing : Keeping it at arms' length. Organisation for Economic Cooperation and Development", The OECD Observer, 230, pp.29~ (2002)
  28. Padmapriya, S., "A case study on femtocell access modes", Engineering Science and Technology, an International Journal, 19(3), pp.1534~1542 (2016)
  29. "Transfer pricing: Decision Making Management Accounting" (2002)[URL]
  30. Perron, S., "Exact and heuristic solutions of the global supply chain problem with transfer pricing", European Journal of Operational Research, 202(3), pp.864~879 (2010)
  31. Peterson, D. F., "Some issues in irrigation macro strategies", Water international, 12(3), pp.102~109 (1987)
  32. Rosenbloom, H. D., "International Tax Arbitrage and the “International Tax System”", Tax Law. Tax Law Review, 53, pp.137~ (2000)
  33. Schuster, P., "Transfer prices : Functions, types, and behavioral implications", Management Accounting Quarterly(Winter), 11(2), pp.22~32 (2010)
  34. Sikka, P., "The dark side of transfer pricing : Its role in tax avoidance and wealth retentiveness", Critical Perspectives on Accounting, 21(4), pp.342~356 (2010)
  35. "Uncovering the bond market spread" (1999)[URL]
  36. Tippett, M., "The teaching of transfer pricing : Theory and examples", Journal of Accounting Education, 24(4), pp.173~196 (2006)
  37. Turner, R., , Study on transfer pricing, 96(10) (1996), The Committee
  38. Profit shifting through transfer pricing: evidence from French firm level trade data, "Vicard, V.", Banque, ~, pp.Banque de France Working Paper 555 (2015)
  39. Warr, Daniel, "Inter-company Transfer Pricing: Documentation and Penalties" (2002), Chartered Accountants
  40. Weichenrieder, A. J., "Profit shifting in the EU : Evidence from Germany", International tax and public finance, 16(3), pp.281~297 (2009)
  41. Wong, H., "Transfer price setting in multinational corporations", International Journal of Business and Social Science, 2(9), pp.10~14 (2011)

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