English, Article, Journal or magazine article edition: International Transfer Pricing for Goods and Intangible Asset Licenses in a Decentralized Multinational Corporation: Review and Extensions Peter C. Dawson; Stephen M. Miller

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Bookmark: http://trove.nla.gov.au/version/183483
Physical Description
  • preprint
Language
  • English

Edition details

Title
  • International Transfer Pricing for Goods and Intangible Asset Licenses in a Decentralized Multinational Corporation: Review and Extensions
Author
  • Peter C. Dawson
  • Stephen M. Miller
Physical Description
  • preprint
Notes
  • Negociated transfer pricing, licensing intangibles, decentralized MNC
  • RePEc:uct:uconnp:2009-06
  • We review and extend the core literature on international transfer price manipulation to avoid or evade taxes. Under negotiated transfer pricing with a viable bargaining structure, including performance evaluation disconnected from the transfer price, divisions voluntarily exchange accurate information to obtain firm-wide optimality, a result not dependent on restraint from exercising internal market power. For intangible licenses, a larger optimal profit shift for a given tax rate change strengthens incentives for transfer pricing abuse. In practice, an intangible’s arm’s length range is viewed as a guideline, a context where incentives for abuse materialize. Transfer pricing for intangibles obliges greater tax authority scrutiny.
  • Negotiated transfer pricing, licensing intangibles, decentralized MNC.
  • RePEc:nlv:wpaper:0901
Language
  • English
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