Governments around the world have regulated multinational enterprises to adopt arm¡¦s length transactions to facilitate identifications and comparisons between non-transfer pricing transactions with independent, non-related enterprises and transactions with related enterprises that are suspected of transfer pricing. Currently, most of the optimal transfer pricing methods for establishing arm¡¦s length principles for multinational enterprises have been addressed in Organization for Economic Cooperation and Development's "Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations". These guidelines emphasize the establishment of a range of arm¡¦s length transactions through the comparability analysis and the economic analysis of transfer pricing transactions; a taxpayer's returns from transactions with related companies are then compared to the range of arm¡¦s length transactions. Currently the academic world is taking the initiative in the development of relevant models to describe corporate transfer pricing decisions or to measure the net income of corporate transfer pricing transactions. This research stems from these purposes and attempts to describe transfer pricing decisions in real practice through stringent modelling; this model is then used to measure the net income of transfer pricing transactions that took place among electronic industry participants who are publicly listed in the TSE or OTC in Taiwan. We further investigated the main factors that affect the levels of net income transferred by enterprises. Based on the empirical results of this research, we discovered that the impact of raw material costs is highly significant to the corporate transfer pricing decisions, and the magnitude of impacts vary depending on the allocation of net income from transfer pricing. We recommend that the tax administration detect corporate transfer pricing decisions by monitoring the weight of raw material costs in a company.
| Identifer | oai:union.ndltd.org:NSYSU/oai:NSYSU:etd-0119110-112200 |
| Date | 19 January 2010 |
| Creators | Huang, Chung-jian |
| Contributors | So-De Shyu, Yong-San Li, Chau-Jung Kuo, Shyan-Rong Chou, Li-Hau Lai, Victor W. Liu |
| Publisher | NSYSU |
| Source Sets | NSYSU Electronic Thesis and Dissertation Archive |
| Language | English |
| Detected Language | English |
| Type | text |
| Format | application/pdf |
| Source | http://etd.lib.nsysu.edu.tw/ETD-db/ETD-search/view_etd?URN=etd-0119110-112200 |
| Rights | withheld, Copyright information available at source archive |
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