IDEAS home Printed from https://ideas.repec.org/p/btx/wpaper/1227.html
   My bibliography  Save this paper

The Increasing Importance of Transfer Pricing Regulations – a Worldwide Overview

Author

Listed:
  • Theresa Lohse

    (University of Mannheim)

  • Nadine Riedel

    (University of Hohenheim, University of Oxford Centre for Business Taxation)

  • Christoph Spengel

    (University of Mannheim, Centre for European Economic Research)

Abstract

As the number of multinational enterprises increases, the number of transactions between entities belonging to the same multinational group rises as well. Intercompany transactions generally offer the opportunity to shift income from one jurisdiction to the other. Income shifting can be driven by tax aspects, for instance a tax rate differential, or by firm-specific tax attributes like tax losses. At the same time, profit shifting imposes risk to governments as it may reduce tax revenues. More and more governments are therefore introducing and extending transfer pricing regulations in order to combat profit shifting through intercompany transactions. This study examines 44 countries and analyses the development of different aspects of transfer pricing regulations over a time period of nine years (2001-2009). In order to show the differences of the regulations in a single measure, an attempt is made to categorize transfer pricing regulations regarding their stringency and impact. The results of the categorization confirm not only the increasing importance of transfer pricing regulations, but also offer very useful and valuable information for future research on the influence of transfer pricing regulations on corporate decisions.

Suggested Citation

  • Theresa Lohse & Nadine Riedel & Christoph Spengel, 2012. "The Increasing Importance of Transfer Pricing Regulations – a Worldwide Overview," Working Papers 1227, Oxford University Centre for Business Taxation.
    • Handle: RePEc:btx:wpaper:1227
    as

    Download full text from publisher

    File URL: https://www.sbs.ox.ac.uk/sites/default/files/Business_Taxation/Docs/WP1227.pdf
    Download Restriction: no
    ---><---

    Citations

    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.
    as


    Cited by:

    1. Thiess Buettner & Michael Overesch & Georg Wamser, 2018. "Anti profit-shifting rules and foreign direct investment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 25(3), pages 553-580, June.
    2. Rathke, Alex A. T., 2015. "Transfer pricing manipulation, tax penalty cost and the impact of foreign profit taxation," EconStor Conference Papers 129075, ZBW - Leibniz Information Centre for Economics.
    3. Christof Ernst & Katharina Richter & Nadine Riedel, 2014. "Corporate taxation and the quality of research and development," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 21(4), pages 694-719, August.
    4. Dinkel, Andreas & Schanz, Deborah, 2015. "Tax attractiveness and the location of patents," arqus Discussion Papers in Quantitative Tax Research 188, arqus - Arbeitskreis Quantitative Steuerlehre.
    5. Kari Seppo, 2015. "Corporate tax in an international environment – Problems and possible remedies," Nordic Tax Journal, Sciendo, vol. 2015(1), pages 1-16, September.
    6. Ji Lee, Ye & Seon Yoo, Ji, 2023. "Loss expectation and income shifting," Journal of Contemporary Accounting and Economics, Elsevier, vol. 19(2).
    7. Egger, Peter H. & Wamser, Georg, 2015. "The impact of controlled foreign company legislation on real investments abroad. A multi-dimensional regression discontinuity design," Journal of Public Economics, Elsevier, vol. 129(C), pages 77-91.
    8. Liliana FELEAGA & Ioana NEAC?U, 2016. "Transfer pricing documentation – an efficient measure for combating the base erosion and profit shifting?," The Audit Financiar journal, Chamber of Financial Auditors of Romania, vol. 14(134), pages 183-183, January.
    9. Ioana NEACSU & Liliana FELEAGA, 2017. "Evolutions and tendencies regarding the Romanian transfer pricing legislation: is there a need for change?," The Audit Financiar journal, Chamber of Financial Auditors of Romania, vol. 15(145), pages 1-65, February.
    10. George Bogdan STAN & Ioan Codruţ TURLEA, 2017. "Risk Estimation of Romanian Large Taxpayers Based on Transfer Pricing Analysis," ECONOMIC COMPUTATION AND ECONOMIC CYBERNETICS STUDIES AND RESEARCH, Faculty of Economic Cybernetics, Statistics and Informatics, vol. 51(3), pages 281-298.
    11. Sebastian Beer & Jan Loeprick, 2015. "Profit shifting: drivers of transfer (mis)pricing and the potential of countermeasures," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 22(3), pages 426-451, June.
    12. Ioana Ignat, 2019. "Transfer Pricing – An Analysis from the Romania`s Perspective," Ovidius University Annals, Economic Sciences Series, Ovidius University of Constantza, Faculty of Economic Sciences, vol. 0(2), pages 755-765, December.
    13. Aaron Flaaen, 2017. "The Role of Transfer Prices in Profit-Shifting by U.S. Multinational Firms : Evidence from the 2004 Homeland Investment Act," Finance and Economics Discussion Series 2017-055, Board of Governors of the Federal Reserve System (U.S.).
    14. Ruud Mooij & Li Liu, 2020. "At a Cost: The Real Effects of Transfer Pricing Regulations," IMF Economic Review, Palgrave Macmillan;International Monetary Fund, vol. 68(1), pages 268-306, March.
    15. Merz, Julia & Overesch, Michael, 2016. "Profit shifting and tax response of multinational banks," Journal of Banking & Finance, Elsevier, vol. 68(C), pages 57-68.
    16. Deborah Schanz & Andreas Dinkel & Sara Keller, 2017. "Tax attractiveness and the location of German-controlled subsidiaries," Review of Managerial Science, Springer, vol. 11(1), pages 251-297, January.

    More about this item

    Keywords

    corporate taxation; transfer pricing; multinational companies;
    All these keywords.

    JEL classification:

    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • K34 - Law and Economics - - Other Substantive Areas of Law - - - Tax Law

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:btx:wpaper:1227. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    We have no bibliographic references for this item. You can help adding them by using this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Dongxian Guo (email available below). General contact details of provider: https://edirc.repec.org/data/sbsoxuk.html .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.