By Moritz Hiemann, Stefan Reichelstein (auth.), Wolfgang Schön, Kai A. Konrad (eds.)
The taxation of firm company teams has develop into a huge drawback within the educational and political debate at the way forward for overseas taxation. particularly the arm’s size regular for the decision of move costs is below expanding strain.
Many international locations and foreign our bodies at the moment are taking a better examine using move costs for revenue moving and are exploring substitute mechanisms equivalent to formulary apportionment for the allocation of taxing rights.
With regard to this subject, this quantity is the 1st to provide a concise research of move pricing within the foreign tax enviornment from an interdisciplinary felony and monetary viewpoint. basics similar to the effective allocation of assets inside multi-unit organisations and distortions among diverse targets of move pricing in addition to diversified features of it in tax and company legislation, the normal OECD technique and functional facets referring to intangibles, capital and possibility allocation are lined by means of impressive authors.
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Extra info for Fundamentals of International Transfer Pricing in Law and Economics
Sample text
Reichelstein (2004), Integrating Managerial and Tax Objectives in Transfer Pricing, Accounting Review 79(3), 591 – 615. Baldenius, T. and S. Reichelstein (2006), External and Internal Pricing in Multidivisional Firms, Journal of Accounting Research 44(1), 1 – 28. Bastian, N. and S. Reichelstein (2005), Transfer Pricing at Timken, Stanford Graduate School of Business, Case # A-190. Boos, M. (2003), International Transfer Pricing: The Valuation of intangible Assets, The Hague, Netherlands Choe, C.
The parent produces a product that is sold directly to the consumers in country A, and is also sold to the consumers in country B through the subsidiary firm, which here takes the form of a retailer. 8 To simplify, without bearing on qualitative results, we assume that demand in both countries is linear and all production costs are constant and normalized to zero. Based on these assumptions, expressions for the firms’ profits (absent taxes) will generally be the following:9 (1) (2) (3) The quantity sold in country i (i = A, B) is denoted by Qi , while an asterisk (*) denotes variables for the local competitor in country B.
In the field of external accounting, the current debate is focused mainly on the role of transfer prices in determining and allocating the income and expense of related business units and in the resulting appropriation of profits. Another key subject is the use of transfer prices as an instrument of tax-optimized profit allocation between different tax jurisdictions. In view of these quite diverse and exacting requirements placed on transfer pricing, the question naturally arises whether a uniform TP can fulfill these demands or whether a more differentiated transfer price design is indeed called for.