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Transfer pricing practices of transnational corporations in PATA countries

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  • Borkowski, Susan C.

Abstract

The tax authorities of Australia, Canada, Japan and the United States formed the Pacific Association of Tax Administrators (PATA) in 1980 to combat income shifting, improve cross-border information flows, and develop conciliatory relationships among themselves. One of their specific concerns was to identify and stop the improper transfer pricing used by transnational corporations (TNCs) to facilitate income shifting and obfuscation of financial data.

Suggested Citation

  • Borkowski, Susan C., 2010. "Transfer pricing practices of transnational corporations in PATA countries," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 19(1), pages 35-54.
  • Handle: RePEc:eee:jiaata:v:19:y:2010:i:1:p:35-54
    DOI: 10.1016/j.intaccaudtax.2009.12.003
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    References listed on IDEAS

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    1. Hines, James R. Jr., 1999. "Lessons From Behavioral Responses to International Taxation," National Tax Journal, National Tax Association;National Tax Journal, vol. 52(2), pages 305-322, June.
    2. Borkowski, Susan C., 2008. "The history of PATA and its effect on advance pricing arrangements and mutual agreement procedures," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 17(1), pages 31-50.
    3. Borkowski, Susan C., 1997. "Factors affecting transfer pricing and income shifting (?) between Canadian and U.S. transnational corporations," The International Journal of Accounting, Elsevier, vol. 32(4), pages 391-415.
    4. Jian Li & Alan Paisey, 2005. "International Transfer Pricing in Asia Pacific," Palgrave Macmillan Books, Palgrave Macmillan, number 978-0-230-51160-6, March.
    5. Borkowski, Susan C., 1996. "An analysis (meta- and otherwise) of multinational transfer pricing research," The International Journal of Accounting, Elsevier, vol. 31(1), pages 39-53.
    6. Jones, C. S., 1985. "An empirical study of the evidence for contingency theories of management accounting systems in conditions of rapid change," Accounting, Organizations and Society, Elsevier, vol. 10(3), pages 303-328, July.
    7. Swieringa, Robert J. & Waterhouse, John H., 1982. "Organizational views of transfer pricing," Accounting, Organizations and Society, Elsevier, vol. 7(2), pages 149-165, April.
    8. Schweikart, James A., 1986. "The relevance of managerial accounting information: A multinational analysis," Accounting, Organizations and Society, Elsevier, vol. 11(6), pages 541-554, October.
    9. Thomas, Andrew P., 1986. "The contingency theory of corporate reporting: Some empirical evidence," Accounting, Organizations and Society, Elsevier, vol. 11(3), pages 253-270, May.
    10. Chenhall, Robert H., 2003. "Management control systems design within its organizational context: findings from contingency-based research and directions for the future," Accounting, Organizations and Society, Elsevier, vol. 28(2-3), pages 127-168.
    11. Jian Li & Alan Paisey, 2005. "Pacific Trade Perspectives," Palgrave Macmillan Books, in: International Transfer Pricing in Asia Pacific, chapter 7, pages 86-102, Palgrave Macmillan.
    12. Hines, James R. Jr., 1999. "Lessons from Behavioral Responses to International Taxation," National Tax Journal, National Tax Association, vol. 52(n. 2), pages 305-22, June.
    13. Spicer, Barry H., 1988. "Towards an organizational theory of the transfer pricing process," Accounting, Organizations and Society, Elsevier, vol. 13(3), pages 303-322, April.
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    Cited by:

    1. Alexander Rogach & Tetyana Balyuk, 2012. "Intra-Firm Transactions of TNCs in Ukraine: Empirical Investigation," Transition Studies Review, Springer;Central Eastern European University Network (CEEUN), vol. 18(3), pages 586-600, March.
    2. Dykxhoorn, Hans J. & Sinning, Kathleen E., 2010. "A review and analysis of international accounting research in JIAAT: 2002–2010," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 19(2), pages 137-153.
    3. Borkowski, Susan C. & Gaffney, Mary Anne, 2012. "FIN 48, uncertainty and transfer pricing: (Im)Perfect together?," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 21(1), pages 32-51.

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    Keywords

    Transfer pricing; Tax audits;

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