The Open UniversitySkip to content
 

Transfer priing and economic functions analysis: the Japanese paradigm

Buckley, Peter J. and Frecknall Hughes, Jane (2000). Transfer priing and economic functions analysis: the Japanese paradigm. In: Buckley, Peter J. ed. Multinational Firms, Cooperation and Competition in the World Economy. Basingstoke, U.K.: Palgrave Macmillan, pp. 123–143.

URL: http://www.palgrave.com/products/title.aspx?pid=26...
Google Scholar: Look up in Google Scholar

Abstract

This paper examines the difficulties facing tax authorities in valuing cross-border flows from a transactions based analysis, in conditions where intangibles and services are important and where the multinational firm concerned is operating a system in which group-wide economic functions dominate decision making. Its key contention is that the economic functions of any entity should be examined in order to determine whether transactions analysis can be used to produce an acceptable value. This is done in the particular context of Japanese multinational enterprises and uses two hypothetical situations to demonstrate the inadequacy of transactions based analysis as a panacea for transfer pricing problems, especially for transfers of value involving intangibles and services, which it redefines into two categories, perceptible and imperceptible.

Item Type: Book Chapter
Copyright Holders: 2000 Macmillan
ISBN: 0-333-75977-X, 978-0-333-75977-6
Academic Unit/Department: Open University Business School
Related URLs:
Item ID: 25071
Depositing User: Catherine Playle
Date Deposited: 22 Mar 2011 16:07
Last Modified: 22 Oct 2012 10:16
URI: http://oro.open.ac.uk/id/eprint/25071
Share this page:

Actions (login may be required)

View Item
Report issue / request change

Policies | Disclaimer

© The Open University   + 44 (0)870 333 4340   general-enquiries@open.ac.uk