外文文献转让定价_策略、实践和税收最小化.pdf

Transfer Pricing: Strategies, Practices, and Tax Minimization Kenneth Klassen Petro Lisowsky Devan Mescall† University of Waterloo University of Illinois University of Saskatchewan kklassen@uwaterloo.ca at Urbana-Champaign mescall@edwards.usask.ca lisowsky@ January 2014 Abstract Using a survey of tax executives from 219 multinational corporations, we investigate the extent to which cross-border transfer prices are a tool for tax minimization. Contrary to common generalizations that multinational firms are chronic tax avoiders, we document that most transfer pricing strategies focus on tax compliance rather than minimizing cash taxes paid. However, firms that focus on minimizing taxes as a goal of transfer pricing do report lower GAAP effective tax rates (ETRs) by approximately 4.1 percentage points, while firms that focus on tax compliance report ETRs that are 3.8 percentage points higher, both relative to firms claiming neither goal. An analysis of our survey firms using Compustat data to calculate various measures of short- and long-run ETRs confirms our survey inferences. We also find that firms that focus on cash taxes report an even lower ETR when the reduction in transfer pricing risk between operating in a tax haven versus non-tax haven is greater. Furthermore, cash tax-oriented firms report higher FIN 48 tax reserves than compliance-oriented firms, suggesting tax minimization for these firms entail uncertain transfer pricing tax arrangements. Finally, larger tax budgets,