The Transfer Pricing Problem: Where the Profits are

36 Pages Posted: 27 Apr 2000 Last revised: 8 Sep 2010

Date Written: December 1990


Section 1 introduces the material. Section 2 of this paper describes the transfer pricing problem and some solutions that have been proposed in the past. Section 3 offers a different solution and demonstrates that it supports an efficient allocation of resources. Section 4 briefly discusses some of the complications that arise in practice, analyzes methods governments have employed to address this problem, and argues that the solution corresponds to concepts of income division that governments have tried to employ in broader contexts.

Suggested Citation

Hines, James Rodger, The Transfer Pricing Problem: Where the Profits are (December 1990). NBER Working Paper No. w3538. Available at SSRN:

James Rodger Hines (Contact Author)

University of Michigan ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States


1050 Massachusetts Avenue
Cambridge, MA 02138
United States

Register to save articles to
your library


Paper statistics

Abstract Views
PlumX Metrics