B The arm’s length principle, transfer pricing, and location choices.doc

The arm’s length principle, transfer pricing, and location choices 在公平的原则，转让定价和位置的选择 Transfer price The arm’s length principle Tax Location choice 转让价格，该公平原则，税收，地点的选择 This paper examines the impacts of the arm’s length principle on tax revenues under endogenous location choices. The results show that the level of transfer price depends not only on taxation policies, but also on ?rms’ location choices. An imposition of the arm’s length principle on a multinational enterprise does not raise tax revenues under endogenous location choices. Such a result is in contrast to the common opinion of tax authorities regarding the regulation on transfer pricing. 本文探讨的公平原则对税收下的内源性区位选择的影响。结果表明，转让价格的高低不仅取决于税收政策，同时也对企业的区位选择。的公平原则，在跨国企业的实施不会引发下，内源性的位置选择的税收收入。这样的结果是相反的税务机关就转让定价监管的共同意见。 1. Introduction The trend of increasing globalization in the world economy has created many new multinational enterprises (hereafter, MNEs) and has also increased the amount of cross-border transactions between their af?liates or related companies. Such transactions often involve the issue of transfer pricing. Transfer pricing is the pricing of internal transactions between subsidiaries or related companies, serving as an important device for a MNE to achieve the goal of maximizing global pro?ts. Nevertheless, tax authorities often claim that transfer pricing deprives governments of their fair share of taxes from global enterprises (Neighbour, 2002). They presume that MNEs use transfer pricing policies to shift pro?ts from high-tax rate countries into low-tax rate countries. To avoid the corresponding loss in tax revenues, tax authorities constantly tighten rules to curb transfer price distortions. From the perspectives of maximizing tax revenues, necessary tax codes must be enacted to prevent such quasi tax savings. As a result, most countries have rules or regulations to assess the appropriateness of the transfer prices quoted by MNEs. 日益全球化的世界经济潮流，创造了许多新的多国企业（以下简称跨国公司），又增加了他们的子公司或关联公司之间的跨境交易量。这种交