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The dark side of transfer pricing: Its role in tax avoidance and wealth retentiveness

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  • Sikka, Prem
  • Willmott, Hugh

Abstract

In conventional accounting literature, ‘transfer pricing’ is portrayed as a technique for optimal allocation of costs and revenues among divisions, subsidiaries and joint ventures within a group of related entities. Such representations of transfer pricing simultaneously acknowledge and occlude how it is deeply implicated in processes of wealth retentiveness that enable companies to avoid taxes and facilitate the flight of capital. A purely technical conception of transfer pricing calculations abstracts them from the politico-economic contexts of their development and use. The context is the modern corporation in an era of globalized trade and its relationship to state tax authorities, shareholders and other possible stakeholders. Transfer pricing practices are responsive to opportunities for determining values in ways that are consequential for enhancing private gains, and thereby contributing to relative social impoverishment, by avoiding the payment of public taxes. Evidence is provided by examining some of the transfer prices practices used by corporations to avoid taxes in developing and developed economies.

Suggested Citation

  • Sikka, Prem & Willmott, Hugh, 2010. "The dark side of transfer pricing: Its role in tax avoidance and wealth retentiveness," CRITICAL PERSPECTIVES ON ACCOUNTING, Elsevier, vol. 21(4), pages 342-356.
    • Handle: RePEc:eee:crpeac:v:21:y:2010:i:4:p:342-356
    DOI: 10.1016/j.cpa.2010.02.004
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    1. Harris, Dg, 1993. "The Impact Of United-States Tax-Law Revision On Multinational-Corporations Capital Location And Income-Shifting Decisions," Journal of Accounting Research, Wiley Blackwell, vol. 31, pages 111-140.
    2. Jack Hirshleifer, 1956. "On the Economics of Transfer Pricing," The Journal of Business, University of Chicago Press, vol. 29, pages 172-172.
    3. Prem Sikka & Colin Haslam & Orthodoxia Kyriacou & Dila Agrizzi, 2007. "Professionalizing Claims and the State of UK Professional Accounting Education: Some Evidence," Accounting Education, Taylor & Francis Journals, vol. 16(1), pages 3-21.
    4. Clausing, Kimberly A., 2003. "Tax-motivated transfer pricing and US intrafirm trade prices," Journal of Public Economics, Elsevier, vol. 87(9-10), pages 2207-2223, September.
    5. Prem Sikka, 2003. "The Role of Offshore Financial Centres in Globalization," Accounting Forum, Taylor & Francis Journals, vol. 27(4), pages 365-399, December.
    6. Borkowski, Susan C., 1997. "The transfer pricing concerns of developed and developing countries," The International Journal of Accounting, Elsevier, vol. 32(3), pages 321-336.
    7. Lorraine Eden & Luis F Juarez Valdez & Dan Li, 2005. "Talk softly but carry a big stick: transfer pricing penalties and the market valuation of Japanese multinationals in the United States," Journal of International Business Studies, Palgrave Macmillan;Academy of International Business, vol. 36(4), pages 398-414, July.
    8. Vladimir Tikhomirov, 1997. "Capital flight from post‐Soviet Russia," Europe-Asia Studies, Taylor & Francis Journals, vol. 49(4), pages 591-615.
    9. Bhat, Ganapati, 2009. "Transfer pricing, tax havens and global governance," IDOS Discussion Papers 7/2009, German Institute of Development and Sustainability (IDOS).
    10. James R. Hines & Eric M. Rice, 1994. "Fiscal Paradise: Foreign Tax Havens and American Business," The Quarterly Journal of Economics, President and Fellows of Harvard College, vol. 109(1), pages 149-182.
    11. Jacob, J, 1996. "Taxes and transfer pricing: Income shifting and the volume of intrafirm transfers," Journal of Accounting Research, Wiley Blackwell, vol. 34(2), pages 301-312.
    12. Picciotto, Sol, 1992. "International taxation and intrafirm pricing in transnational corporate groups," Accounting, Organizations and Society, Elsevier, vol. 17(8), pages 759-792, November.
    13. Alex Cobham (QEH), "undated". "Tax Evasion, Tax Avoidance and Development Finance," QEH Working Papers qehwps129, Queen Elizabeth House, University of Oxford.
    14. Berry, A. J. & Capps, T. & Cooper, D. & Ferguson, P. & Hopper, T. & Lowe, E. A., 1985. "Management control in an area of the NCB: Rationales of accounting practices in a public enterprise," Accounting, Organizations and Society, Elsevier, vol. 10(1), pages 3-28, January.
    15. Chan, K. Hung & Chow, Lynne, 1997. "An empirical study of tax audits in China on international transfer pricing," Journal of Accounting and Economics, Elsevier, vol. 23(1), pages 83-112, May.
    16. P. B. Oyelere & C. R. Emmanuel, 1998. "International transfer pricing and income shifting: evidence from the UK," European Accounting Review, Taylor & Francis Journals, vol. 7(4), pages 623-635.
    17. Klassen, K & Lang, M & Wolfson, M, 1993. "Geographic Income Shifting By Multinational-Corporations In Response To Tax Rate Changes," Journal of Accounting Research, Wiley Blackwell, vol. 31, pages 141-173.
    18. Cools, Martine & Emmanuel, Clive & Jorissen, Ann, 2008. "Management control in the transfer pricing tax compliant multinational enterprise," Accounting, Organizations and Society, Elsevier, vol. 33(6), pages 603-628, August.
    19. Alfons Weichenrieder, 1996. "Fighting international tax avoidance," Fiscal Studies, Institute for Fiscal Studies, vol. 17(1), pages 37-58, February.
    20. Rudiger Ahrend, 2004. "Accounting for Russia's Post-Crisis Growth," OECD Economics Department Working Papers 404, OECD Publishing.
    21. Mr. Jack M. Mintz, 1998. "The Role of Allocation in a Globalized Corporate Income Tax," IMF Working Papers 1998/134, International Monetary Fund.
    22. Gunter, Frank R., 2004. "Capital flight from China: 1984-2001," China Economic Review, Elsevier, vol. 15(1), pages 63-85, January.
    23. Messaoud Mehafdi, 2000. "The Ethics of International Transfer Pricing," Journal of Business Ethics, Springer, vol. 28(4), pages 365-381, December.
    24. Weinthal, Erika & Jones Luong, Pauline, 2001. "Energy wealth and tax reform in Russia and Kazakhstan," Resources Policy, Elsevier, vol. 27(4), pages 215-223, December.
    25. John Christensen & Richard Murphy, 2004. "The Social Irresponsibility of Corporate Tax Avoidance: Taking CSR to the bottom line," Development, Palgrave Macmillan;Society for International Deveopment, vol. 47(3), pages 37-44, September.
    26. Eden, Lorraine & Dacin, M. Tina & Wan, William P., 2001. "Standards across borders: crossborder diffusion of the arm's length standard in North America," Accounting, Organizations and Society, Elsevier, vol. 26(1), pages 1-23, January.
    27. Mr. Vito Tanzi, 2000. "Globalization, Technological Developments, and the Work of Fiscal Termites," IMF Working Papers 2000/181, International Monetary Fund.
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