Management control in the transfer pricing tax compliant multinational enterprise

This paper studies the impact of transfer pricing tax compliance on management control system (MCS) design and use within one multinational enterprise (MNE) which employed the same transfer prices for tax compliance and internal management purposes. Our analysis shows immediate effects of tax compliance on the design of organising controls with subsequent effects on planning, evaluating and rewarding controls which reveal a more coercive use of the MCS overall. We argue that modifications to the MCS cannot be understood without an appreciation of the MNEs’ fiscal transfer pricing compliance process.     

The use of information technology for international transfer pricing in multinational enterprises

This paper studies the degree to which multinational enterprises (MNEs) use information technology for managing international transfer pricing (ITP). Based on 21 interviews conducted with in-house accounting and tax professionals in MNEs, we observed limited use of information technology for ITP management. However, some degree of ITP automation was observed in workflow management to produce transfer pricing documentation. The limited degree of automation observed was driven by both system- and individual-level barriers. Overall, we found that management accountants and information technology experts dominate the enterprise resource planning system design agenda, and the tax departments’ ITP tax compliance objective plays a relatively limited role. This reduces the ability for ITP automation partly because the data segmentation that is prioritized for management reporting does not support the tax departments’ needs for legal-entity data segmentation to document tax compliance.     

Transfer pricing as a tax compliance risk

This paper studies the role of transfer pricing as a critical compliance issue. Specifically, we analyse whether and to what extent the perceived risk associated with transfer pricing responds to country-, industry- and firm-specific characteristics. Empirically, transfer pricing risk awareness is measured as a professional assessment reported by the person with ultimate responsibility for transfer pricing in their company. Based on a unique global survey conducted by a Big 4 accounting firm in 2007 and 2008, we estimate the number of firms reporting transfer pricing being the largest risk issue with regard to subsequent tax payments. We find that transfer pricing risk awareness depends on variables accounting for general tax and transfer pricing specific strategies, the types and characteristics of intercompany transactions the multinational firms are involved in, their individual transfer pricing compliance efforts and resources dedicated to transfer pricing matters.     

Overhead allocation: a cautionary tale!

This paper examines the behavioural consequences of charging/allocating central overheads to profit centres within a UK public sector institution. It is based on actual events at a UK university and the issues are set out in a case study format using correspondence from the profit centre manager to highlight issues of contol and measurement. A number of student tasks are suggested that require students to think beyond accounting numbers and consider the potentially conflicting roles of accounting information. In particular there is a conflict between the need to recover full costs from the University/Head Office perspective and the potential alienation of profit centre managers with only crude models for overhead recovery. The problems caused by inappropriate communication of accounting data and reactions to that data are also considered and instructors may use the case to introduce students to the differences between profit and not-for-profit organizations.     

Tariff elimination versus tax avoidance: free trade agreements and transfer pricing

International Tax and Public Finance - We explore the new roles of rules of origin (ROO) when multinational enterprises (MNEs) manipulate their transfer prices to avoid a high corporate tax. The...     

Tax strategy control: The case of transfer pricing tax risk management

This paper examines how a functional tax strategy impacts the management control system (MCS) in a multinational enterprise (MNE) facing transfer pricing tax risks. Based on case study findings it is argued that the MCS in a multinational setting is contingent upon the MNE's response to its tax environment. Moreover, the paper extends existing contingency-based theory on MCS by illustrating the role of inter-organisational network collaboration across MNE transfer pricing tax experts. This collaboration, caused by a widely dispersed tax knowledge base, fuels the formal interactive control system and reduces tax uncertainty. The paper adopts an interdisciplinary approach for explaining findings, using contingency-based theory and network theory at the inter-organisational level.     

Entry deterrence through credible commitment to transfer pricing at direct cost

This paper examines the choice between direct and absorption costing in a cost-based transfer pricing system for duopolistic firms competing with product market prices. Existing literature has shown that the adoption of an absorption costing system, which drives up the intrafirm transfer price, strategically dominates direct costing for the two firms, regardless of whether the transfer price is publicly observable, thereby constituting a subgame perfect Nash equilibrium (SPNE). However, we demonstrate that direct costing can strategically dominate absorption costing when one of the two firms is an incumbent, whereas the other is a potential entrant. Stated differently, the well-known result in the strategic cost allocation problem reverses if we consider entry threats. More specifically, we show that if the incumbent credibly commits to an observable transfer price, the upfront adoption of a direct costing system enables the incumbent to deter the entry of the potential rival in the SPNE. As a commitment device for the observable price, we consider the regulation of transfer prices that usually exists in oligopolistic network industries. We show that a regulator that pursues social welfare maximization approves direct costing but not absorption costing. Therefore, the firms and the regulator can share a mutual interest in the adoption of a direct costing system, a state thus sustained as the SPNE. This result yields managerial accounting implications for a divisionalized firm facing the threat of potential competitors entering the market in that the firm can use this accounting system to help monopolize the market.     

The dark side of transfer pricing: Its role in tax avoidance and wealth retentiveness

In conventional accounting literature, ‘transfer pricing’ is portrayed as a technique for optimal allocation of costs and revenues among divisions, subsidiaries and joint ventures within a group of related entities. Such representations of transfer pricing simultaneously acknowledge and occlude how it is deeply implicated in processes of wealth retentiveness that enable companies to avoid taxes and facilitate the flight of capital. A purely technical conception of transfer pricing calculations abstracts them from the politico-economic contexts of their development and use. The context is the modern corporation in an era of globalized trade and its relationship to state tax authorities, shareholders and other possible stakeholders. Transfer pricing practices are responsive to opportunities for determining values in ways that are consequential for enhancing private gains, and thereby contributing to relative social impoverishment, by avoiding the payment of public taxes. Evidence is provided by examining some of the transfer prices practices used by corporations to avoid taxes in developing and developed economies.     

对企业所得税税前扣除制度最新变化的分析

为适应我国财会制度改革和加强企业所得税管理的需要,进一步规范现行企业所得税税前扣除,不久前同家税务总局发布了《企业所得税税前扣除办法》(以下简称《办法》),这一办法与现行的企业所得税税前扣除制度相比,有较大的变化.     

ICT deployment and resource-based power in multinational enterprise futures

Applying a resource-dependency perspective to intra-multinational enterprise (MNE) power [55] and [56], this paper examines the effect of the deployment of advanced ICT and particularly the implementation of enterprise resource planning (ERP) systems. Although subsidiaries in the multinational do not have authority-based or ‘structural’ power with respect to key strategic decisions [6] and [16], they may have ‘resource-based’ power in the form of knowledge and capabilities that is of value to the multinational as a whole. Business network analysis highlights the ‘invisibility’ of the external networks (often in the host country) to the upper echelons in the multinational through which valuable subsidiary knowledge and capabilities develop. It points out that this ‘invisibility’ undermines the headquarters’ ability to control the subsidiary [3], [28], [36], [44], [70] and [74]. In this paper we argue that the deployment of ERP undermines the resource base of subsidiary power and thus helps to restore greater central authority in the MNE. The paper reports findings from studies in twelve MNEs which have implemented ERP and points out that from the perspective of subsidiary managers a key effect of ERP deployment is the reduction in their autonomy. This may have significant adverse implications for the futures of the MNE as a federative organizational form and the legitimacy of MNE operations abroad.     

Taxpayers' responsiveness to tax rate changes and implications for the cost of taxation in Sweden

Historically, labor supply elasticities have been used to evaluate tax policy and predict tax revenue effects. They are likely to underestimate taxpayers' response to tax rate changes, and hence to underestimate changes in potential tax revenues, however, because they measure only how taxpayers alter hours worked. Taxpayers can also respond to tax rate changes by altering, for instance, their work effort and form of compensation. An alternative measure that accounts for these responses as well as hours worked is the elasticity of taxable income. This paper estimates the elasticity of earned taxable income for Swedish taxpayers using two different approaches and a number of control variables and the 1990/1991 tax reform as a “natural experiment”. The preferred elasticity estimates fall in the range of 0.4–0.5, comparable with recent estimates for the U.S. and larger than most of the labor supply elasticity estimates used to evaluate tax policy in Scandinavia previously, which suggests that deadweight losses are two to three times higher than previously thought. JEL Classification H21 · H24 · H31 · J22     

The effects of tax rate changes on tax bases and the marginal cost of public funds for Canadian provincial governments

The efficiency losses from taxation vary directly with the responsiveness of a government??s tax bases to tax-rate increases. We estimate the dynamic responses of tax bases to changes in tax rates using aggregate panel data from Canadian provinces over the period 1972 to 2006. Our preferred empirical results indicate that a one percentage point increase in corporate income, personal income, and sales tax rates is associated with a 3.67, 0.76, and 1.17 percent reduction in their respective tax bases in the short run. The corresponding long-run tax base semi-elasticity estimates are higher: ?13.60, ?3.63, and ?3.18, respectively. We use the tax base elasticity estimates to calculate the marginal cost of public funds (MCF) for the provinces?? three major taxes. Our computations indicate that the corporate income had the highest MCF and that the sales tax had the lowest MCF in all provinces in 2006. The MCF for the personal income tax ranged from 1.44 in Alberta to 3.81 in Quebec. Our results imply that there would have been significant welfare gains in 2006 from reductions in provincial corporate income tax rates. Our computations also indicate that the equalization grant formula may reduce the perceived MCF of the provinces that receive these grants, and that increases in provincial corporate and personal income taxes can cause significant reductions in federal tax revenues.     

An application of opportunity cost for a short-run pricing decision

This article illustrates how opportunity cost can be provided as an explicit information item for a manager's short-run pricing decision. By using an example of a special order decision situation, the article shows the merits of using an opportunity cost approach instead of using only a direct cost or an absorption cost approach.     

Adjustment costs of institutional tax changes from the audit pricing perspective: Empirical evidence from the VAT reform

Institutional changes inevitably impose adjustment costs on firms while also generating benefits. However, empirical evidence regarding the adjustment costs of institutional changes is limited, with much of the focus centered on benefits. Using data on China’s A-share listed companies from 2010 to 2018 and the nation’s staggered adoption of the “business tax to value-added tax reform” (hereafter, “VAT reform”) as a natural experiment, we examine the impact of this reform on a particular corporate cost: audit fees. We find audit fees to be 8.11% higher for VAT reform firms than for non-VAT reform firms. This difference does not exist before or after the reform year. That is, it is only observed in the year of VAT reform implementation. This indicates the existence of an adjustment cost specifically related to the VAT reform. Furthermore, we observe larger fee increases among firms audited by Big 4 international audit firms, firms that require more audit work, firms that are more complex, and firms with weak internal controls. From the audit pricing perspective, we provide evidence of the economic consequences of tax reform. The corporate adjustment costs that arise from institutional changes deserve more attention from decision-makers.     

The incentive to locate a multinational firm: The effect of tax reforms in the United Kingdom

The advent of the single European market has focused attention on the structure of international tax incentives for the location of multinational business. Multinationals that channel foreign income through the United Kingdom have been likely to suffer double taxation in the form of surplus advance corporation tax when they subsequently distribute the income to a foreign parent. This paper shows that the 1993 U.K. tax reforms create a significant reduction in the tax cost of locating in the United Kingdom, relative to traditionally favorable tax regimes such as the Netherlands.     

Transferring priorities: a three-act play on transfer pricing

We present the discourse which surrounds the implementation of a transfer pricing system for a major company in the financial services sector. This discourse is superficially mundane and yet constitutes a problematic piece of text for which several readings are possible. Rather than close down interpretation by imposing a single reading, we develop a critique which juxtaposes critical perspectives and references to the text. The paper illustrates the many ways in which critical perspectives are relevant to an understanding of practice. In broad terms, the power of accounting is illustrated through its agenda-shaping potential, and shaping the agenda is shown to be capable of countering this power. A final section suggests that critical perspectives offer a more enlightened and optimistic programme than does the discourse of transfer pricing, which is to be found in practice.     

Dividend tax signaling and the pricing of future earnings: a case of taxable stock dividends

The purpose of our study is to explore what types of information content are conveyed by dividends on future earnings. We examine this issue by investigating the effect of dividends on the association between current year stock returns and future earnings (i.e. the future earnings response coefficient, FERC). Based on exploring the Taiwan market, our results reveal that taxable stock dividends enhance the FERC while nontaxable stock dividends do not, consistent with the tax-based signaling argument. We also find a positive relation between cash dividends and the FERC in firms with severe free cash flow problems, and this suggests that higher cash payouts mitigate manager over-investment so future earnings are more highly valued, consistent with the agency argument. Our main contributions are to specify what factors make dividends informative with regard to future earnings and the provision of evidence to support the tax-based signaling model.     

Endogenous choice on tax instruments in a tax competition model: unit tax versus ad valorem tax

This paper analyzes an endogenous choice problem with regard to tax instruments in a capital tax competition model. Using a symmetric and two-region model of tax competition, where each region is allowed to choose either a unit or an ad valorem tax, we show that selecting a unit tax as a policy instrument is the dominant strategy.