Distortions Caused by the Use of Arm's Length Transfer Prices.
研究了税务上使用正常交易标准确定转移价格造成的经济扭曲，聚焦可比非受控价格法，发现该方法在垂直整合集团内分配给制造商的单位毛利比例高于其与独立卖方交易时的水平。
Abstract This paper examines the economic distortions caused by the use of the arm's-length standard when determining transfer prices for tax purposes. It focuses on the Comparable Uncontrolled Price (CUP) method. The fact that the vertically integrated form of business is selected to make sales in one country and not in another suggests that key factors relevant to the organizational form choice differ between the two countries. Thus, independent and affiliated organizations will operate under inherently different conditions because the variations in economic conditions, themselves, cause the same manufacturers to use both independent and related sellers for different countries at the same time. The analysis of the consequences of using the CUP method for tax purposes within the vertically integrated group, given double marginaliization between independent parties, shows that the CUP method allocates to the manufacturer a higher proportion of the gross margin per unit than that earned by the manufacturer when it deals with an unrelated seller.