管理层自主权与税收合规:国际转让定价的实证研究

Managerial Autonomy and Tax Compliance: An Empirical Study on International Transfer Pricing

Journal of the American Taxation Association · 2006
被引 34
ABS 3

中文导读

研究了外国子公司管理层自主权如何影响其通过国际转让定价进行利润转移的行为,发现自主定价或自主采购的子公司税收审计调整更小。

Abstract

This paper examines the impact of managerial autonomy on tax compliance in an international transfer pricing context. Specifically, we study whether foreign subsidiaries' autonomy in making pricing and sourcing decisions on intrafirm transfers affect their profit shifting through international transfer pricing. We measure transfer pricing noncompliance in terms of tax audit adjustments made by tax authorities. Based on a sample of 163 transfer pricing audits on foreign investment enterprises (FIEs) in China, we find that tax audit adjustments for FIEs that have autonomy in setting transfer prices or sourcing from outsiders are smaller than those that have their transfer transactions dictated by parent companies.

转让定价税收合规跨国公司审计调整