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Conflicting Transfer Pricing Incentives and the Role of Coordination

https://doi.org/10.2139/ssrn.1609697
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The 23 checked references that resolve
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no DOI — not checkedU.S. Income Tax Transfer Pricing Rules and Resource Allocation: The Case of Decentralized Multinational Firms
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no DOI — not checkedPct_Export and Pct_Import measure the significance of international trade for the firm as the ratio of total U.S. exports to total U.S. sales, and the ratio of total U.S. imports to total U.S. sales, respectively. Column (5) reports results using SizeDum as our measure of Corp-Coordination. SizeDum equals 1 if logFirmAssets is below the median of the sample distribution, 0 otherwise, where logFirmAssets is the natural log of firm total assets. logPTI equals the natural log of foreign affiliate pre-tax income. ITPI measures the income tax transfer pricing incentive and is equal to (t f -t US ), where t f equals the ratio of foreign income tax expense to pre-tax income, and t US equals the U.S. statutory rate. Conflict25, Conflict50, and Conflict75 are indicator variables equal to 1 if Conflict is equal to 1 and Duty (net of the income tax benefit) is greater than 25, 50, and 75 percent, respectively, of the income tax transfer pricing incentive (e.g., the absolute value of ITPI). Conflict equals 1 when both Buyer and High-Income-Tax are equal to 1, or both Buyer and High-Income-Tax are equal to 0, 0 otherwise where Buyer equals 1 if the foreign affiliate buys from its U.S. parent and High-Income-Tax equals 1 if t f > t US . Duty is the average country-year import duty rate, as reported by the World Bank, net of the income tax rate in the country of the buyer: t f or t US . logAssets equals the natural log of foreign affiliate total assets. logComp equals the natural log of foreign affiliate total employee compensation. logGDP equals the natural log of gross domestic product in the foreign affiliate's country, as reported by the Economist Intelligence Unit. unless otherwise noted. Column (1) reports results using One_Authority as our measure of Gov't-Coordination. One_Authority equals 1 if the revenue body and customs agency are formally integrated into a single governmental authority, 0 otherwise, as reported by the OECD. Column (2) reports results using One_Audit as our measure of Gov'tCoordination. One_Audit equals 1 if the revenue body conducts tax audits such that multiple types of tax liabilities are audited simultaneously, 0 otherwise, as reported by the OECD. Column (3) reports results using Centralized as our measure of Corp-Coordination
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