Decentralization and Transfer Pricing Under Oligopoly

This paper presents a simple model of a partially decentralized multinational firm (MNF) in competition with a rival firm. It is shown that transfer pricing can be used as a rent-shifting device by the MNF to compete with the rival. This arises because the MNF headquarters uses the transfer price to manage different subsidiaries. The specific value of the transfer price chosen by the MNF depends on whether the rival firm produces the intermediate good, the final good, or both and whether the rival is integrated or not. In particular, both decentralization and competition with a fully integrated rival result in lower transfer prices.     

跨国公司无形资产转移定价税制研究

转移定价是跨国公司常用的一种避税手段,由此产生的国际税收问题引起各国的普遍关注。随着全球化大生产和知识经济的发展,跨国公司无形资产内部交易日渐频繁,相关税制的不完善使国家的税收权益存在巨大隐患。本文结合国内外无形资产转移定价税制特别是各种定价方法的介绍,评析了我国相关税制存在的问题并提出了自己的建议,希望对推进我国相关领域的税制改革有所助益。     

Transfer Pricing: Strategies,Practices, and Tax Minimization

Using a survey of tax executives from multinational corporations, we document that some firms set their transfer pricing strategy to minimize tax payments, but more firms focus on tax compliance. We estimate that a firm focusing on minimizing taxes has a GAAP effective tax rate that is 6.6 percentage points lower and generates about $43 million more in tax savings, on average, than a firm focusing on tax compliance. Available COMPUSTAT data on sample firms confirm our survey‐based inferences. We also find that transfer pricing‐related tax savings are greater when higher foreign income, tax haven use, and R&D activities are combined with a tax minimization strategy. Finally, compliance‐focused firms report lower FIN 48 tax reserves than tax‐minimizing firms, consistent with the former group using less uncertain transfer pricing arrangements. Collectively, our study provides direct evidence that multinational firms have differing internal priorities for transfer pricing, and that these differences are strongly related to the taxes reported by these firms.     

Transfer pricing and developing countries: Some problems of investigation

This paper reviews some of the main problems which arise for developing host countries in the investigation of transfer pricing of commodity trade by transnational corporations in manufacturing industry. The paper deals in turn with the following: the problems raised by the fact that the extent of intra-firm trade and the potential for manipulating transfer prices from case to case, especially because of the nature of technological innovation; the main handicaps faced by host developing country governments in collecting data on transfer pricing; and, the difficult conceptual issues that arise in defining the correct reference prices by which transfer prices may be judged. It concludes with the suggestion that intercountry cooperation is the most promising course of action in order to surmount these problems.     

产业集群下在华跨国公司转移定价行为路径选择

本文系统归纳总结了跨国公司转移定价的产生、发展、定价方法,结合我国产业集群背景下跨国公司转移定价管制的现状,阐述了我国的应对政策。     

国际关联方交易内部结转价格的所得税税收和会计策略

国际关联方交易的内部结转价格是指跨国公司内部各个实体之间销售产品或者提供劳务所使用的一种内部划拨价格。跨国公司利用内部结转价格可以达到缴纳最少所得税等目的,国际上为了有效地对跨国公司国际关联方交易的内部结转价格在所得税方面进行税务和会计监督,执行着＂局外价格＂、＂比较价格＂和要求跨国公司揭示更多的财务信息的三种方法。文章认为,无论哪种方法都存在缺乏在世界范围内的统一规范、统一运作和统一监督的问题,应该成立一个由经济专家、会计专家和税务官员组成的全世界范围内的协会或组织予以协调。在我国应该结合具体国情选择相应的方法,并逐步向＂局外价格＂和＂比较价格＂过渡。     

预约转让定价的博弈分析

国际关联交易中,跨国公司常常根据各国税制差异利用转让定价套取税收利益,逃避税收。我国作为吸引外国直接投资最多的国家之一,也面临由此产生的税收大量流失的严重问题。本文通过构建预约定价中参与人之间的博弈模型,对其进行分析,提出相应措施,对进一步完善反避税制度具有重要意义。     

地方政府土地市场行为的经济学分析

当前,城市非理性扩张、房价不断攀升、土地市场秩序混乱等问题日益凸显,这离不开地方政府的土地市场行为。文章重点分析了地方政府的土地征购、出让定价、实物地租转嫁以及协议出让等行为,指出中央——地方的财政竞争以及地区之间的平行竞争是其深层次的制度根源,而中国土地制度的产权缺陷决定地方政府对土地市场的“事实垄断”为其提供了现实基础。因此,规避地方政府行为对经济的不利影响,必须明确地方政府土地市场的监管职能,深化土地市场改革,充分发挥市场机制的基础性作用。     

试论跨国采购风险管理与企业社会责任

众多跨国公司越来越重视研究跨国采购的风险管理。而企业社会责任风险这种近年来日益明显的风险,正在成为跨国采购风险管理中越来越重要的组成部分。本文将主要分析如何识别和管理跨国采购的一般风险,尤其是如何判断和防范社会责任风险。同时跨国采购中的社会责任风险管理也正在极大地影响着我国的跨国采购供应商,本文也将分析我国供应商如何应对跨国公司的这类采购风险管理。     

企业绿色创新对审计定价的影响——基于我国上市公司绿色专利数据的证据

基于2010—2021年沪深A股上市公司数据，实证分析企业绿色创新对审计定价的影响，以期为强化审计监督赋能绿色发展提供一定的理论依据与经验参考。研究发现，企业绿色创新能够提升审计定价水平，且企业可持续经营在企业绿色创新与审计定价中发挥着中介效应，是企业绿色创新促进审计定价水平提升的重要路径。进一步分析发现，机构投资者持股能够缓解企业绿色创新与审计定价的正相关关系。异质性检验发现，企业绿色创新与审计定价的正相关关系在民营企业中更显著。     

International business alliances: an incomplete contract approach

This paper is an attempt to utilize an incomplete contract approach to explain various forms of alliances in international business. We present a simple model of vertical integration as internalization. It provides theoretical foundations to understand the multinational enterprise's choice between inter-firm transactions and intra-firm transactions. In a simple framework, we provide a rationale for joint ventures, original equipment manufacturing (OEM), cross-licensing and divestment by focusing on the subcontractor's incentives. Moreover, we discuss transfer pricing and some policies such as incentives, taxation, and local content requirements.     

Freedom and management in primary commodity markets: US imports from developing countries

New US data are employed to ascertain the share which intra-firm transactions make up of US primary commodity imports. This share is frequently very high and, for many commodities, well above the average for total US imports. An attempt to explain divergences between intra-firm prices and average prices by differential tax rates and foreign exchange controls yielded only weak results in the cases of bananas, iron ore, rubber and tea but strong ones in that of coffee. Analysis of transfer pricing behaviour is clearly very important in many commodity markets but requires more data than could here be brought to bear.     

跨国经营企业公司治理结构评价及实证研究

一个企业若要在激烈的国际竞争中立于不败之地,完善的公司治理结构是不可或缺的。文章运用层次分析法和模糊综合评价法构建了跨国经营企业公司治理模式评价体系,并进行实证研究。解决因跨国经营所面临的复杂环境而带来的公司治理问题,已经成为管理学界和企业界普遍关注的焦点。     

Conflicting Transfer Pricing Incentives and the Role of Coordination

Our study evaluates the role of coordination, at both the government and the firm level, on the transfer prices set by U.S. multinational corporations (MNCs) when income taxes and duties cannot be jointly minimized with a single transfer price. We find that either the presence of a coordinated income tax and customs enforcement regime or coordination between the income tax and customs functions alters transfer prices for these firms. Our analyses have implications for both firms and taxing authorities. Specifically, our findings suggest that MNCs might decrease their aggregate tax burdens by increasing coordination within the firm or that governments might increase their aggregate revenues by improving coordinating enforcement across taxing authorities. Our study is novel in that we document, in a specific setting, how coordination influences MNCs’ tax reporting behavior.     

Internalization is still a general theory of foreign direct investment

Conclusions Part IV of Parry's article discusses three types of FDI activity by MNEs; these are correctly analyzed and fully consistent with my earlier work. All the three cases (vertical integration, transfer pricing and quality control) are examples of market imperfections which lead to internalization. I am glad that Parry accepts these“three areas where internalization appears to provide an explanation of FDI as a specific form of international involvement by the MNE” but I am surprized that he still cannot accept the general point that these are examples of“market failure” in an international context, which lead to multinational hierarchical activity. The focus of my survey article was to demonstrate that“established theories of FDI” tend to fasten one to one or another of such market imperfections, but in all cases internalization results. Internalization as a general theory of FDI is still a robust principle. It provides the conceptual foundation for analysis of the MNE and the field of international business.     

预约定价与税收公平原则关系之探究

预约定价作为调整跨国公司转移定价的新制度体现了税收效率原则,但这一制度是否同样体现了税收公平原则值得认真研究。本文通过对预约定价与税收公平原则相互关系的剖析,重点考察了预约定价影响税收公平原则的若干因素,并结合我国预约定价的实践,得出了相应的结论。     

The training and spread of managerial know-how,a comparative analysis of multinational and other firms in Kenya

This article investigates an area of multinational corporate activity in less developed countries (LDCs) that has hithero gone unexplored, namely their training of indigenous managers and the spread of this transferred know-how throughout the host country economy. The significance of management training for the successful transfer of technology is discussed in the introduction, followed by a presentation of the methodology employed; data regarding the extent and composition of management training offered to local managers is analyzed, and conclusions regarding the extent and significance of management training by multinationals in LDCs are drawn.     

Do Institutional Investors Prefer Near‐Term Earnings over Long‐Run Value?*

This paper examines whether institutional investors exhibit preferences for near‐term earnings over long‐run value and whether such preferences have implications for firms' stock prices. First, I find that the level of ownership by institutions with short investment horizons (e.g., “transient” institutions) and by institutions held to stringent fiduciary standards (e.g., banks) is positively (negatively) associated with the amount of firm value in expected nearterm (long‐term) earnings. This evidence raises the question of whether such institutions myopically price firms, overweighting short‐term earnings potential and underweighting long‐term earnings potential. Evidence of such myopic pricing would establish a link through which institutional investors could pressure managers into a short‐term focus. The results provide no evidence that high levels of ownership by banks translate into myopic mispricing. However, high levels of transient ownership are associated with an over‐ (under‐) weighting of near‐term (long‐term) expected earnings, and a trading strategy based on this finding generates significant abnormal returns. This finding supports the concerns that many corporate managers have about the adverse effects of an ownership base dominated by short‐term‐focused institutional investors.     

Optimal Monopolist Export Pricing with Dynamic Demand and Learning Curve Effects

This paper addresses incomplete exchange rate pass-through (ERPT) and pricing-to-market (PTM) by proposing an optimal control model of dynamic monopolistic pricing on a foreign market, which accounts for dynamic demand effects (such as diffusion or saturation) and learning curve effects. It is shown how the optimal dynamic export pricing results in partial or full ERPT in the long-term equilibrium. Moreover, transitional price dynamics are illustrated, which may explain dumping, i.e., temporary prices below unit costs, and (asymmetric) short-run overshooting dynamics of the optimal export price level as a reaction to exchange rate changes.     

Taxicab regulation in Japan

This paper proposes a model of a cruising taxicab industry under laissez faire pricing and free entry, and compares it with alternative regimes including collusive fare setting, collusive restrictions on entry, or both. In the model, under laissez faire, prices are determined by Nash bargaining with complete information and lie above marginal costs. Under laissez faire pricing and free entry the average number of vacant cabs need not be efficient and could be either higher than optimal or less, depending upon the relative bargaining power of individual cabs and potential customers. Under collusive control of entry, the average number of vacant cabs will be set at the efficient level given the prices, which if set collusively will be above the laissez faire prices. These findings shed new light on the political success of cartelizing regulation of the cruising taxicab industry such as that observed in Japan. J. Japanese Int. Economies 20 (2) (2006) 288–304.