Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/96895 
Year of Publication: 
2014
Series/Report no.: 
CESifo Working Paper No. 4694
Publisher: 
Center for Economic Studies and ifo Institute (CESifo), Munich
Abstract: 
Against a background of rather mixed evidence about transfer pricing practices in multinational enterprises (MNEs) and varying attitudes on the part of tax authorities, this paper explores how multiple aims in transfer pricing can be pursued across four different transfer pricing regimes. A MNE has a production subsidiary in one country, from where it sells the produced good locally as well as to a sales subsidiary in a second country. The latter subsidiary is engaged in duopolistic competition with a local competitor. The MNE has two aims in setting the transfer price: strategic delegation and tax minimization. We examine the extent to which the four transfer pricing regimes we set up allow the MNE to pursue these aims. While neither strategic delegation nor tax minimization will be eliminated, trade-offs are inevitable, albeit to varying degree.
Subjects: 
transfer prices
strategic delegation
tax manipulation
MNEs
JEL: 
H25
F23
H87
M48
Document Type: 
Working Paper
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