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International transfer pricing and income shifting: evidence from the UK

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  • P. B. Oyelere
  • C. R. Emmanuel

Abstract

The potential use of international transfer pricing (ITP) as an income-shifting mechanism by multinational enterprises (MNEs) has long been recognized. However, there is relatively little evidence to substantiate or discount this claim in relation to UK-based foreign-controlled enterprises (FCEs). This paper examines the possible use of ITP as an income-shifting mechanism by FCEs operating in the UK. The methodological approach involves the comparison of the profitability (performance) and dividend (post-performance) distributions of a sample of FCEs with those of UK-controlled enterprises (UKCEs) over a two-year period. The two samples are matched on the basis of their total assets (capability). Results reveal significant differences in the profitability and dividend distributions of the two groups. FCEs underperform UKCEs, but their level of dividend distribution outstrips those of UKCEs. Based on this sample of seventy-two companies, a firm is more likely to be an FCE, rather than a UKCE, if it reports a combination of lower performance and higher post-performance distribution. Evidence of significant income shifting by FCEs is confirmed and the claim that ITP is the key mechanism for such shifts cannot be dismissed.

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  • 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.
    • Handle: RePEc:taf:euract:v:7:y:1998:i:4:p:623-635
    DOI: 10.1080/096381898336222
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    3. K. Chan & Lynne Chow, 2001. "Corporate environments and international transfer pricing: an empirical study of China in a developing economy framework," Accounting and Business Research, Taylor & Francis Journals, vol. 31(2), pages 103-118.
    4. Arnt Ove Hopland & Petro Lisowsky & Mohammed Mardan & Dirk Schindler, 2014. "Income Shifting under Losses," CESifo Working Paper Series 5130, CESifo.
    5. 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.
    6. John Christian Langli & Shahrokh Saudagaran, 2004. "Taxable income differences between foreign and domestic controlled corporations in Norway," European Accounting Review, Taylor & Francis Journals, vol. 13(4), pages 713-741.
    7. Bakke, Julia Tropina & Hopland, Arnt Ove & Møen, Jarle, 2019. "Profit shifting and the effect of stricter transfer pricing regulation on tax revenue," Discussion Papers 2019/11, Norwegian School of Economics, Department of Business and Management Science.
    8. Sven P. Jost & Michael Pfaffermayr & Hannes Winner, 2014. "Transfer pricing as a tax compliance risk," Accounting and Business Research, Taylor & Francis Journals, vol. 44(3), pages 260-279, June.
    9. Richardson, Grant & Taylor, Grantley & Lanis, Roman, 2013. "Determinants of transfer pricing aggressiveness: Empirical evidence from Australian firms," Journal of Contemporary Accounting and Economics, Elsevier, vol. 9(2), pages 136-150.
    10. Dirk Schindler & Guttorm Schjelderup, 2016. "Multinationals and Income Shifting by Debt," International Journal of the Economics of Business, Taylor & Francis Journals, vol. 23(3), pages 263-286, September.
    11. Messaoud Mehafdi, 2000. "The Ethics of International Transfer Pricing," Journal of Business Ethics, Springer, vol. 28(4), pages 365-381, December.
    12. Ricardo Santos & Samuel Pereira & Elísio Brandão, 2016. "Transfer Pricing Aggressiveness And Financial Derivatives Practices: Empirical Evidences From United Kingdom," FEP Working Papers 583, Universidade do Porto, Faculdade de Economia do Porto.
    13. Brandstetter, Laura, 2014. "Do Corporate Tax Cuts Reduce International Profit Shifting?," Discussion Papers 2014/10, Free University Berlin, School of Business & Economics.
    14. Brandstetter, Laura, 2014. "Do corporate tax cuts reduce international profit shifting," arqus Discussion Papers in Quantitative Tax Research 162, arqus - Arbeitskreis Quantitative Steuerlehre.

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