Tax-motivated transfer mispricing in South Africa: Direct evidence using transaction data
利用南非海关交易数据，首次直接证明发展中国家跨国公司通过操纵转移价格将利润转移至低税国，发现进口商品导致的税收损失占公司税款的0.5%，并评估了OECD改革的效果。
This paper provides the first direct systematic evidence of profit shifting through transfer mispricing in a developing country. Using South African transaction-level customs data, I directly test for transfer price deviations from arm's-length pricing. I find that multinational firms in South Africa manipulate transfer prices in order to shift taxable profits to low-tax countries. The estimated tax loss relating to imported goods alone is 0.5% of corporate tax payments. My estimates do not support the common belief that transfer mispricing in South Africa is more severe than in advanced economies. I find that an OECD-recommended reform had no long-term impact on transfer mispricing but argue that the method used in this paper provides a cost-efficient way to curb transfer mispricing.