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Treatment of Intercompany Transfer Pricing for Tax Purposes : A Survey of Legislative and Administrative Issues
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ISBN: 1462398413 145528582X 1281345407 1455299839 9786613778970 Year: 1992 Publisher: Washington, D.C. : International Monetary Fund,

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Abstract

Tax authorities in several countries have intensified their surveillance of intercompany transfer pricing in recent years. This paper examines the legislative and administrative issues related to the treatment of intercompany transfer pricing for tax purposes. It reviews the existing international guidelines and national rules on methods for determining appropriate transfer prices, as well as the issues related to tax administration practices for the implementation of those rules. Various systems, proposed or introduced to improve the predictability of taxation, are also examined. This paper further reviews the recent discussions on the “commensurate-with-income” standard and the pricing methodologies proposed thereunder. It finally reviews some alternative approaches to international income allocation which are proposed or adopted in lieu of the transfer pricing approach.


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At A Cost: the Real Effects of Transfer Pricing Regulations
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ISBN: 1484351533 1484351479 Year: 2018 Publisher: Washington, D.C. : International Monetary Fund,

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Unilateral adoption of transfer pricing regulations may have a negative impact on real investment by multinational corporations (MNCs). This paper uses a quasi-experimental research design, exploiting unique panel data on domestic and multinational companies in 27 countries during 2006-2014, to find that MNC affiliates reduce their investment by over 11 percent following the introduction of transfer pricing regulations. There is no significant reduction in total investment by the MNC group, suggesting that these investments are most likely shifted to affiliates in other countries. The impact of transfer pricing regulations corresponds to an increase in the ``TPR-adjusted' corporate tax rate by almost one quarter.


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The Impact of Profit Shifting on Economic Activity and Tax Competition
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Year: 2019 Publisher: Washington, D.C. : International Monetary Fund,

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A growing empirical literature has documented significant profit shifting activities by multinationals. This paper looks at the impact of such profit shifting on real activity and tax competition. Real activity can be affected as profit shifting changes—and theoretically most likely reduces—the cost of capital. Tax competition, even over real capital, is affected, because a permissive attitude toward profit shifting can be seen as a selective tax reduction for multinationals. Tightening profit shifting rules in turn can affect tax competition through the main rate. This paper discusses these issues theoretically and with the help of a simulation to assess the impact of profit-shifting on investment, revenues, and government behavior. Using the theoretical framework, it also provides a brief overview of the related empirical literature.


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The Impact of Profit Shifting on Economic Activity and Tax Competition
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ISBN: 1513525069 Year: 2019 Publisher: Washington, D.C. : International Monetary Fund,

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Abstract

A growing empirical literature has documented significant profit shifting activities by multinationals. This paper looks at the impact of such profit shifting on real activity and tax competition. Real activity can be affected as profit shifting changes—and theoretically most likely reduces—the cost of capital. Tax competition, even over real capital, is affected, because a permissive attitude toward profit shifting can be seen as a selective tax reduction for multinationals. Tightening profit shifting rules in turn can affect tax competition through the main rate. This paper discusses these issues theoretically and with the help of a simulation to assess the impact of profit-shifting on investment, revenues, and government behavior. Using the theoretical framework, it also provides a brief overview of the related empirical literature.


Book
Is There Money on the Table? Evidence on the Magnitude of Profit Shifting in the Extractive Industries.
ISBN: 151356742X Year: 2021 Publisher: Washington, D.C. : International Monetary Fund,

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Profit shifting remains a key concern in international tax system debate, but discussions are largely based on aggregate estimates, with less attention paid to individual sectors. Drawing on a novel dataset, we quantify tax avoidance risks in the extractive industries, a sector which is revenue critical for many developing economies. We find that a one percentage point increase in the domestic corporate tax rate has historically reduced sectoral profits by slightly over 3 percent; and the response tends to be more pronounced among mining than among hydrocarbon firms. There is only weak evidence transfer pricing rules contain tax minimization efforts of MNEs in our sample, but interest limitation rules (e.g., thin capitalization or earnings based rules) do reduce the observable extent of profit shifting. Our findings highlight the challenge of taxing income in the natural resource sector and suggest how fiscal regime design might be strengthened.


Book
Administering fiscal regimes for extractive industries
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ISBN: 1498316921 1475556810 9781475556810 1513515594 9781484386446 1484386442 1475575173 9781475575170 1322028117 9781322028118 1513516051 9781513516059 9781484386088 1484386086 9781513567891 1513567896 148438637X 1513512994 1513536184 1498316875 Year: 2014 Publisher: Washington, DC International Monetary Fund

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This handbook is one of the first of its kind to focus attention on effectively administering revenues from extractive industries. It provides policymakers and officials in developing and emerging market economies with practical guidelines to establish a robust legal framework, organization, and procedures for administering revenue from these industries. It discusses transparency and how to promote it in the face of increasing demands for clarity and how developing countries can strengthen their managerial and technical capacity to administer these revenues.

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