Abusive Transfer Pricing and Economic Activity

21 Pages Posted: 18 Jun 2014

See all articles by Soren Bo Nielsen

Soren Bo Nielsen

Copenhagen Business School - Department of Economics; Centre for Economic Policy Research (CEPR); CESifo (Center for Economic Studies and Ifo Institute)

Dirk Schindler

Erasmus School of Economics; CESifo (Center for Economic Studies and Ifo Institute)

Guttorm Schjelderup

Norwegian School of Economics (NHH) - Department of Business and Management Science

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Date Written: May 30, 2014

Abstract

This paper investigates how concealment costs of transfer pricing and the probability of detection affect transfer pricing and firm behavior. We find that transfer pricing in intermediate production factors does not affect real activity of a multinational firm if the firm’s concealment effort as well as the probability of being audited by tax authorities are conditioned on the amount of shifted profits. If tax authorities rely on the standard OECD arm’s-length principle instead by reacting to a deviation of the transfer price from the market price, the multinational will for tax reasons adjust its production structure. A policy implication of the paper is that it should be preferable to condition audits on the amount of income shifted rather than on the distortion of the transfer price proper. Another policy finding is that improving the quality of tax law might be superior to higher detection effort. The former reduces profit shifting and concealment effort, whereas the latter leads to more wasteful use of resources on concealment and has an ambiguous effect on profits shifted.

Keywords: Transfer Pricing; Firm Behavior; Tax Law

JEL Classification: H20

Suggested Citation

Nielsen, Soren Bo and Schindler, Dirk and Schjelderup, Guttorm, Abusive Transfer Pricing and Economic Activity (May 30, 2014). NHH Dept. of Business and Management Science Discussion Paper No. 2014/21. Available at SSRN: https://ssrn.com/abstract=2451055 or http://dx.doi.org/10.2139/ssrn.2451055

Soren Bo Nielsen

Copenhagen Business School - Department of Economics ( email )

Porcelænshaven 16 A, 1
Frederiksberg C, DK-2000
Denmark

Centre for Economic Policy Research (CEPR)

London
United Kingdom

CESifo (Center for Economic Studies and Ifo Institute)

Poschinger Str. 5
Munich, DE-81679
Germany

Dirk Schindler

Erasmus School of Economics ( email )

P.O. Box 1738
3000 DR Rotterdam
Netherlands

CESifo (Center for Economic Studies and Ifo Institute)

Poschinger Str. 5
Munich, DE-81679
Germany

Guttorm Schjelderup (Contact Author)

Norwegian School of Economics (NHH) - Department of Business and Management Science ( email )

Helleveien 30
Bergen, NO-5045
Norway

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