Background
Transfer pricing refers to the pricing of goods, services, and intangibles transferred within divisions of a multinational corporation. These prices are used in transactions between companies that are part of the same larger organization but operate in different countries. The primary goal of transfer pricing is to ensure that transactions between divisions or subsidiaries align with market rates, thus reflecting genuine commercial activity rather than manipulated profits.
Historical Context
The term and the concept of transfer pricing became increasingly significant in the 20th century, mirroring the globalization of businesses and the rise of multinational corporations. By the latter half of the century, as international trade grew, companies realized that transfer pricing could affect their financial health, taxation responsibilities, and regulatory surveillance. Consequently, countries began to implement diverse rules to prevent transfer pricing abuse.
Definitions and Concepts
Transfer pricing involves setting a price for transactions performed between affiliated entities, such as divisions of one corporation in different countries. The fundamental concept adheres to the “arm’s length principle,” which means the transfer price should be equivalent to what would be charged between unrelated parties under comparable conditions.
Major Analytical Frameworks
Classical Economics
In classical economics, there is limited focus on transfer pricing as research primarily revolves around open-market conditions and not internal transactions within firms.
Neoclassical Economics
Neoclassical economics introduces the idea of firms maximizing profits, and within this context, transfer pricing emerged as a strategic aspect of resource allocation within firms to achieve this goal, particularly across international borders.
Keynesian Economics
Although Keynesian economics emphasizes aggregate demand and overall economic policies, it indirectly touches upon transfer pricing as firms manipulate internal transfers to respond to tax policies and regulations, affecting national economic dynamics.
Marxian Economics
Marxian economics would critique transfer pricing as a method to practice surplus value extraction and enhance capital accumulation beyond local jurisprudence boundaries, emphasizing the unequal distribution of wealth across nations driven by capitalistic multinationals.
Institutional Economics
In Institutional economics, transfer pricing is seen as part of the greater framework of organizational behavior within corporations, drawing attention to how institutional rules, both formal and informal, affect and dictate these internal pricing policies.
Behavioral Economics
From the perspective of behavioral economics, transfer pricing may be influenced by the cognitive biases of corporate leaders making decisions under conditions of taxation, international regulation, and competitive pressure.
Post-Keynesian Economics
Post-Keynesian analysis understands transfer pricing as part of firm strategies to handle uncertainty and invest resources while tackling fiscal policies, regulatory stipulations, and long-term growth impacts.
Austrian Economics
Austrian economics might stress the subjective value judgement in individual decision-making within firms, including setting transfer prices, reflecting the differing costs and demand schedules regionally identified by division managers.
Development Economics
Transfer pricing affects development economics significantly by influencing the tax base of developing countries, and sparking concerns about base erosion and profit shifting (BEPS), which hampers these countries’ abilities to mobilize sufficient domestic resources.
Monetarism
Monetarism would consider transfer pricing within its critical examination of how firms’ practices directly impact monetary flow, inflation, domestic investment, and ultimately national economic policies.
Comparative Analysis
Globalization implies various international rules and penalties concerning transfer pricing, creating disparities in its management across countries. Advanced economies tend to have rigorous frameworks against mispricing practices tied to transfer prices to prevent tax base erosion, whereas developing nations struggle with capacity and resource constraints to implement similar controls effectively.
Case Studies
Apple Inc.
Apple Inc.’s strategies have used transfer pricing to allocate profits to subsidiaries in low-tax jurisdictions, thereby reducing effective tax rates on their worldwide income. This has encouraged comprehensive global scrutiny and changes.
Google Ireland
Notably, Google employs transfer pricing to shift profits to its Ireland subsidiary to take advantage of favorable tax rates, another example closely examined by authorities for regulatory adjustments.
Suggested Books for Further Studies
- “International Transfer Pricing in Asia Pacific” - Jenny Lim
- “Transfer Pricing and Corporate Taxation: Problems, Practical Implications and Proposed Solutions” - Elizabeth King
- “Global Transfer Pricing Solutions” - John Henshall
Related Terms with Definitions
- Arm’s Length Principle: The condition where a transaction is conducted as if the entities involved are unrelated, ensuring market-comparable pricing.
- Base Erosion and Profit Shifting (BEPS): Strategies multinational companies use to shift profits from high tax jurisdictions to locations with lower taxes.
- Multinational Corporation (MNC): A corporate organization that owns or controls production or service facilities in one or more countries other than its home country.
- Tax Haven: A country or jurisdiction with very low or even zero taxes, used by companies to minimize tax liabilities.
By understanding transfer pricing
