Transfer Pricing: A Tax Avoidance Tool of Multinational Corporations

2014 ◽  
Author(s):  
Muideen Adeseye Awodiran
Keyword(s):  
Multinational Corporations ◽  
Transfer Pricing ◽  
Tax Avoidance

scholarly journals PENGAMBILAN KEPUTUSAN TRANSFER PRICING PADA PERUSAHAAN MULTINASIONAL BERDASARKAN TAX DAN EXCHANGE RATE

2018 ◽  
Vol 11 (1) ◽  
Author(s):  
Suryani Cahyadi ◽  
Budi Kurniawan
Keyword(s):  
Logistic Regression ◽  
Exchange Rate ◽  
Multinational Corporations ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Categorical Variables ◽  
Manufacturing Companies ◽  
Positive Direction ◽  
Tax Rate ◽  
Pricing Decisions

<p><em>The objective of this research is to prove, analyze the influence of tax and exchange rate on transfer pricing decision in multinational manufacturing companies. Tax is measured using a proxy ETR (Effective Tax Rate), Exchange Rate is measured using a proxy keutungan or loss transactions of companies using foreign currency, and transfer pricing was measured using dummy variables to determine the companies that conduct transactions with related parties.</em><em> </em><em>The analysis technique used in this research is regression analysis with the use of categorical variables logit model (Logistic Regression / Binary Choice) or also called logistic regression using EViews 9.5 program for Windows.</em><em> </em><em>Based on the results of logistic regression analyzes tested, testing the first hypothesis (H<sub>1</sub>) of positive influence Tax on transfer pricing decisions of companies, the result is precisely the opposite direction to that predicted, namely tax significant negative effect on the company transfer pricing decisions. While testing the second hypothesis (H<sub>2</sub>) on the effect of Exchange Rate on transfer pricing decisions the company showed a positive direction but not significant. The results of this study indicate that the tax and exchange rate does not significantly influence transfer pricing indications. The determination coefficient (McFadden R-squared) is 0.023610. This result show that 2.3%  transfer pricing is affected by tax, and exchange rate. While the rest 97.7% is explained by other variable that means many other variables in outside of tax, and exchange rate that can explain transfer pricing.</em><em> </em><em>Transfer pricing happen on the company with high profit purpose and using tax avoidance become the a to fulfil it, but the higher the tax rate used by the company will lower the company's transfer pricing decisions. The amount of the exchange rate (exchange rate) affects the judgment of the company, whether the company will choose to conduct transfer pricing decisions, or choose not to take a decision of transfer pricing.</em></p><p><em> </em></p><p><strong><em>Keywords:</em></strong><em> </em><em>tax, exchange rate, transfer pricing, multinational corporations</em></p>

Transfer pricing, earnings management and tax avoidance of firms in Ghana

2019 ◽  
Vol 26 (1) ◽  
pp. 235-259 ◽  
Author(s):  
Mohammed Amidu ◽  
William Coffie ◽  
Philomina Acquah
Keyword(s):  
Earnings Management ◽  
Multinational Corporations ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Pricing Strategies ◽  
Data Set ◽  
Content Type ◽  
Financial Firms ◽  
Key Variables ◽  
Almost All

Purpose This paper aims to investigate how transfer pricing (TP) and earnings management affect tax avoidance of firms in Ghana. Design/methodology/approach The authors use a panel data set from 2008 to 2015 to further shed light on transfer pricing-tax avoidance nexus by examining the complex interaction of three key variables: transfer pricing, earnings management and tax avoidance. Findings The results show that almost all the sample firms have engaged in some form of transfer pricing strategies and the manipulation of earnings to avoid tax during 2008-2015. There is evidence to suggest that non-financial multinational corporations manipulate more earnings than the financial firms while financial firms also use more TP than non-financial firms. The overall results suggest that the sensitivity of tax avoidance to transfer pricing decreases as firms increase their earnings management. By extension, these results have important policy implication for policymakers in assessing the effectiveness of tax laws relating to transfer pricing. Originality/value The authors investigate how transfer pricing and earnings management affect the avoidance of firms operating in Ghana.

Thin Capitalization, Transfer Pricing Aggresiveness, Penghindaran Pajak

2018 ◽  
Vol 2 (1) ◽  
pp. 1-28
Author(s):  
Teza Deasvery Falbo ◽  
Amrie Firmansyah
Keyword(s):  
Regression Analysis ◽  
Linear Regression ◽  
Stock Exchange ◽  
Transfer Pricing ◽  
Linear Regression Analysis ◽  
Tax Avoidance ◽  
Total Sample ◽  
Multiple Linear Regression Analysis ◽  
Tax Revenue ◽  
Thin Capitalization

The increase in tax revenue in Indonesia is not accompanied by an increase in tax ratio The low tax ratioindicatestax avoidance practices in Indonesia. Some tax avoidance practices can be conductedthrough transferpricing and thin capitalization.This study is aimed to examine empirically the effect of thin capitalization as well astransfer pricing aggressiveness on tax avoidance practice in Indonesia. This study uses manufacturing companieswhich are listed on Indonesia Stock Exchange (IDX) within the period 2013-2015. Using purposive sampling, theselected samples in this study are 90 companies, so the total sample is 270 samples. The hypothesis examinationused in this study is multiple linear regression analysis of panel data.The results of this study suggest that thincapitalization is positively associated with tax avoidance,while transfer pricing aggressivenessis not associated withtax avoidance.

scholarly journals Assessing impact of base erosion and profit shifting on performance of subsidiaries of multinational corporations in Baltic countries

Equilibrium ◽  
2019 ◽  
Vol 14 (2) ◽  
pp. 277-293
Author(s):  
Egidijus Kundelis ◽  
Renata Legenzova
Keyword(s):  
Multinational Corporations ◽  
Empirical Research ◽  
Tax Avoidance ◽  
Empirical Literature ◽  
Company Performance ◽  
Tax Rates ◽  
Profit Shifting ◽  
Baltic Countries ◽  
The Baltic ◽  
The Impact

Research background: The problem of base erosion and profit shifting by multi-national corporations has been debated from different perspectives because of its multiple impact on the key actors in the economy. Studies refer to its positive impact on companies via corporate taxes saved, but its negative impact on governments via reduced tax collection. A number of empirical studies conducted in different countries support the substantial BEPS impact on company performance, but report differences in its magnitude. Other authors claim that, despite a wide range of tax avoidance opportunities available, tax avoidance is limited due to institutional measures imposed (tax audits, penalties for non-compliance) and high implementation costs. A majority of the previous empirical research covered large countries (USA, Germany) or regions (e.g. Europe), but there is a gap in the re-search assessing the BEPS impact on multinational corporations’ subsidiaries’ performance in countries with lower corporate income tax rates such as the Baltic countries. Purpose of the article: To assess the impact of base erosion and profit shifting on multinational corporations’ subsidiaries’ performance in the Baltic countries. Methods: Empirical research is conducted based on the framework employed by Hines and Rice (1994) to measure BEPS impact on company performance. Regression analysis with fixed effects was applied to a sample of 3,422 Latvian, Lithuanian and Estonian subsidiaries of multinational corporations, which are characterized by low corporate tax rates.  The data for the period of 2007–2015 was retrieved from the Amadeus database. Findings & Value added: The research revealed that Baltic countries’ tax differentials between multinational corporations’ parent and subsidiary countries might have a significant impact on the subsidiary’s financial performance. When the tax rate differences between Baltic and the foreign countries decrease by 1%, reported profits in Baltic countries increase by 2.3%, indicating profit-shifting behaviour. This is in line with the empirical literature and practices applied by multinational corporations. It is also in favour of anti-tax avoidance measures introduced by the EC to be adopted by Baltic and other EU countries.

scholarly journals Corporate Income Shifting in an Era of Tax Multilateralism: The Impact of Exchange-of-Information Agreements

2021 ◽  
Vol 69 (2) ◽  
pp. 357-389
Author(s):  
Devan Mescall ◽  
Paul Nielsen
Keyword(s):  
Multinational Corporations ◽  
Multinational Enterprises ◽  
Transfer Pricing ◽  
Empirical Studies ◽  
Annual Reports ◽  
Income Shifting ◽  
Exchange Of Information ◽  
Pricing Rules ◽  
Using Data ◽  
The Impact

Using data from the annual reports of over 100,000 subsidiaries of multinational enterprises (MNEs) from 55 countries between 2003 and 2012, the authors of this article investigate the impact of exchange-of-information agreements ("EOI agreements") on tax-motivated income shifting. Transparency created by the signing of EOI agreements is expected to reduce the tax-motivated shifting of income by multinational corporations. Whether such agreements affect the income-shifting behaviour of multinational corporations is an unanswered question. The authors find evidence that, on average, EOI agreements do have an impact on tax-motivated income shifting. Additionally, they find that more advanced, modern EOI agreements are associated with a larger decrease in tax-motivated income shifting compared to the impact of early EOI agreements. This evidence challenges the prevalent assumption in empirical studies that EOI agreements are homogeneous. Supplemental analyses suggest that factors that affect the information asymmetry between MNEs and tax authorities, such as corporations with high levels of intangibles and tax authorities with strong transfer-pricing rules and enforcement, can diminish or enhance the effectiveness of EOI agreements in moderating tax-motivated income shifting. The evidence provided by this study shows that consideration of the tax authorities' information environment and the substance of an EOI agreement is essential when assessing the impact of such an agreement on the tax behaviour of sophisticated taxpayers such as multinational corporations.

scholarly journals Income Tax Complexity Faced by Multinational Corporations: A Comparative Study of Canada, the United States, and Other Selected OECD Countries

2021 ◽  
Vol 69 (3) ◽  
pp. 745-790
Author(s):  
Susann Sturm
Keyword(s):  
United States ◽  
Multinational Corporations ◽  
Income Tax ◽  
Transfer Pricing ◽  
The United States ◽  
Oecd Countries ◽  
The Us ◽  
Tax Complexity ◽  
Medium Level ◽  
Foreign Corporations

This study examines the complexity of Canada's corporate income tax system from the perspective of multinational corporations and compares it with the complexity of the US system, also taking into account measures of complexity for 19 other member countries of the Organisation for Economic Co-operation and Development (OECD). The author finds that with regard to the Canadian tax code, the most complex laws are those on corporate reorganization, transfer pricing, and controlled foreign corporations, and with regard to the Canadian tax framework, the most complex areas are tax audits, tax-law enactment, and tax guidance. In comparison with other OECD countries, Canada is remarkably similar to the United States. Both countries have a medium level of overall complexity, and both have a more complex tax code but a less complex tax framework than other countries. However, a closer examination of the Canadian and US tax codes and tax frameworks reveals some significant differences in complexity levels, particularly in respect of certain tax laws.

scholarly journals The Use of International Tax Planning in Subsidiaries from the Financial and ICT Sectors in the Czech Republic

2021 ◽  
Vol 24 (1) ◽  
pp. 182-196
Author(s):  
Vít Jedlička
Keyword(s):  
Global Economy ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Tax Planning ◽  
Tax Burden ◽  
Effective Tax Rate ◽  
Tax Havens ◽  
Tax Rate ◽  
Dummy Variable ◽  
International Tax

Tax avoidance is an important element of management in the global economy. Managers use tax havens for reducing a company’s effective tax rate. The most common practices in international tax planning can be divided into three groups: loans and their related interest, royalties, and transfer pricing. The aim of this article is to find the determinants of the tax burden faced by foreign-owned subsidiaries. Therefore, a model was created for the tax burden, focusing on the special position of subsidiaries within international tax planning. For this purpose, taxes/outcomes was established as a new dependent variable. The panel data used include Czech companies that are owned by parent companies located in other EU countries. The model distinguishes EU tax havens from regular member states; sector dummy variables are also included. The regression model that was created did not confirm the assumed dependencies. Rather, it indicated other important determinants: profitability, the share of intangible assets, size, and the dummy variable for the ICT sector. Based on the regression results, the independent variables connected with known tax planning schemes have relatively low importance. The significance of these results can be seen in the subsequent conclusions. First of all, there is no difference between the subsidiaries’ tax burdens based on the parent company’s location. Corporations use international tax planning whether or not they are owned from a tax haven. The second significant conclusion indicates the importance of certain sectors and their attributes concerning the tax burden. Companies from the ICT sector are linked to a lower tax burden. On the other hand, the dependencies within the financial sector are not statistically significant. From the perspective of further research, it would be constructive to incorporate the subsidiary’s position within the group.

scholarly journals Do Government Regulations Prevent Transfer Pricing Manipulations?

2011 ◽  
Vol 4 (10) ◽  
Author(s):  
Canri Chan
Keyword(s):  
Multinational Corporations ◽  
Transfer Pricing ◽  
Cash Flows ◽  
Transfer Price ◽  
Tax Rates ◽  
Performance Measurements ◽  
Government Regulations ◽  
Transfer Prices ◽  
Profit Performance ◽  
Efficient Allocations

This study investigated the effects of government regulations and incentives on the setting of transfer prices. I found significant main effects of both variables on transfer price choices. Transfer pricing is important, particularly for Multinational Corporations (MNCs), because of increased trends toward globalization of business activities and, simultaneously, decentralization. These trends have led to increased pressures for sound internal pricing systems, specifically transfer pricing, in order for organizations to ensure optimal and efficient allocations of organization resources and to provide profit performance measurements (Tang 1992). It has generally been recognized in the literature that in order to maximize after tax cash flows, MNCs shift profits from high to low tax jurisdictions. Governments in some countries, particularly those with high tax rates, are greatly concerned as to whether or not companies attempt to avoid tax liabilities via transfer pricing manipulation, specifically in terms of trying to shift profits to lower tax jurisdictions, and have enacted laws to limit transfer price choice.

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