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Tax and tariff planning through transfer prices: The role of the head office and business unit

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  • Kohlhase, Saskia
  • Wielhouwer, Jacco L.

Abstract

We study the roles of the head office (HO) and the business units (BUs) of a multinational corporation (MNC) in reducing income tax and tariff payments through internal transfer prices in international trades. Using confidential transfer price data of a large MNC, we analyze how the different elements of internal transfer prices set by the HO and BUs vary differently from external prices with income tax rates, tariff rates, and the tradeoff between the two. Absent severe agency conflicts, we find that the BUs contribute more to tax planning than the HO, despite that explicit incentives to do so are not included in the compensation schemes. The roles of the HO and BUs vary with product market competition, the risk of conflicts with tax and customs authorities, and agency problems within the firm. Moreover, we provide evidence of strategic trade cost allocations among BUs to reduce income taxes.

Suggested Citation

  • Kohlhase, Saskia & Wielhouwer, Jacco L., 2023. "Tax and tariff planning through transfer prices: The role of the head office and business unit," Journal of Accounting and Economics, Elsevier, vol. 75(2).
    • Handle: RePEc:eee:jaecon:v:75:y:2023:i:2:s016541012200091x
    DOI: 10.1016/j.jacceco.2022.101568
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    Cited by:

    1. Rainer Niemann & Mariana Sailer, 2023. "Is analytical tax research alive and kicking? Insights from 2000 until 2022," Journal of Business Economics, Springer, vol. 93(6), pages 1149-1212, August.
    2. Giese, Henning & Koch, Reinald & Sureth, Caren, 2024. "Where to locate tax employees? The role of tax complexity and tax risk implications," arqus Discussion Papers in Quantitative Tax Research 285, arqus - Arbeitskreis Quantitative Steuerlehre.

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    More about this item

    Keywords

    Tax optimization; Tariff optimization; Multinational corporations; Transfer price; Incoterms;
    All these keywords.

    JEL classification:

    • D22 - Microeconomics - - Production and Organizations - - - Firm Behavior: Empirical Analysis
    • D23 - Microeconomics - - Production and Organizations - - - Organizational Behavior; Transaction Costs; Property Rights
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance
    • L21 - Industrial Organization - - Firm Objectives, Organization, and Behavior - - - Business Objectives of the Firm
    • M41 - Business Administration and Business Economics; Marketing; Accounting; Personnel Economics - - Accounting - - - Accounting

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