Transfer pricing as a tax compliance risk |
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Authors: | Sven P Jost Michael Pfaffermayr |
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Institution: | 1. Department of Economics and Statistics, University of Innsbruck, Universitaetsstrasse 15, A-6020 Innsbruck, Austria;2. International Tax Services – Transfer Pricing, Ernst &3. Young LLP, 8484 Westpark Drive, McLean, VA 22102, USA;4. Austrian Institute of Economic Research (WIFO), Universitaetsstrasse 15, A-6020 Innsbruck, Austria |
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Abstract: | 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. |
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Keywords: | international taxation multinational firms transfer pricing |
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