By Jian Li, Alan Paisey
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Extra resources for International Transfer Pricing: Perspectives on Trade Between Australia, New Zealand and China
Sample text
Tax underpayments caused by the movement of profits out of a country can result in shortfalls in government revenue and in foreign exchange reserves. In past years, the number of multinational enterprises operating in developing countries has increased significantly. Items of anecdotal evidence suggest that multinational enterprises operating in developing countries have considerable income shifting opportunities by International Transfer Pricing. One explanation for this is the lack of institutional frameworks and administrative expertise in host countries to deal with the situation.
They are faced with an ‘economic environment…much more complex and perplexing than that for domestic transfers…’ (Wu and Sharp, 1979, p. 83). Within the host country they are focused on minimising tax liabilities, reducing tariffs on imports and exports, avoiding restrictions on the repatriation of profits, minimising foreign exchange risks, enhancing the competitive position of subsidiaries in international markets, and improving the relations between subsidiaries and foreign host governments. At the international level, the objectives and motivations associated with transfer pricing revolve around issues of taxation and duties.
These taxes account for up to a third of revenue in some developing countries’ (Cohen, 1995, p. 11). Therefore, the nature of International Transfer Pricing can have significant tax implications for their developing economies. 3 Influential Regulations Introduction As more and more of the world’s trade is conducted through multinational intercompany networks, the temptation for multinational enterprises to indulge and contrive price manipulation is high. The tax authorities of many governments have begun to expand their concern with respect to the abusive nature of multinational transfer pricing practices.
