转让定价规制与税收竞争

Transfer pricing regulation and tax competition

Journal of International Economics · 2020
被引 66
人大 AABS 4

中文导读

研究了跨国公司利用转让定价避税的动机,以及转让定价规制如何影响税收竞争和社会福利,发现适度容忍利润转移可能提升福利,且规制严格时母国愿提高税率。

Abstract

The paper analyzes multinational enterprises' incentives to manipulate internal transfer prices to take advantage of tax differences across countries, and implications of transfer-pricing regulations as a countermeasure against such profit shifting. We find that tax-motivated foreign direct investment (FDI) may entail inefficient internal production but may benefit consumers. Thus, encouraging transfer-pricing behavior to some extent can enhance social welfare. Furthermore, we consider tax competition between two countries to explore its interplay with transfer-pricing regulations. We show that the FDI source country will be willing to set a higher tax rate and tolerate some profit shifting to a tax haven country if the regulation is tight enough. We also indicate a novel mechanism through which it is the larger country that undertakes tax-motivated FDI, the pattern we often observe in reality.

转让定价规制税收竞争利润转移跨国企业