بررسی بیشتر تغییر درآمد از طریق قیمت گذاری انتقالی با در نظر گرفتن حجم و یا آشفتگی شرکت

This study evaluates the effect of firm size on income shifting between tax jurisdictions through the use of transfer prices both before and after the passage of the Tax Reform Act of 1986 (TRA86). Prior research addressing income shifting through transfer pricing analyzes larger, financially sound firms. This empirical study extends the transfer pricing literature by including smaller and in some cases financially distressed firms in the sample and testing the effect by firm size on income shifting. Our findings suggest that smaller and/or distressed firms are less likely to shift income through transfer pricing than larger firms.

This study extends the investigation of income shifting through transfer pricing to include smaller, less multinational firms. We extend the literature by replicating Jacob's (1996) study using an expanded sample of firms and by analyzing the results by size. This helps eliminate the survivorship bias that existed in earlier studies and gives us a better understanding of the size effect and characteristics of firms that income shift. By expanding the sample used by Jacob (1996) to include firms with missing information on COMPUSTAT, we show that firms that income shift using transfer prices tend to be larger, less-financially distressed firms that are included in the databases commonly used for empirical work. Jacob (1996) found that “firms with substantial international intrafirm transfers pay lower global taxes than otherwise similar firms in both the pre- and post-TRA86 periods, but these same firms appear to have paid lower US taxes than otherwise similar firms in the pre-TRA86 period and higher US taxes in the post-TRA86 period.” This result supports the use of transfer prices to minimize global taxes. Using an expanded sample of firms, we find that the factors identified by Jacob are indeed important. However, the explanatory power of the models is reduced and the size variable becomes a significant factor in explaining the level of global and US taxes in the pre-TRA86 period. In addition, we find that the level of intrafirm transfers is no longer a significant factor in determining US taxes in the post-TRA86 period. This result is consistent with previous research by Klassen et al. (1993). We find that the profitability difference between US and foreign operations is consistent with income shifting through transfer pricing only in the post-TRA86 period. Jacob (1996) found a significant result in both periods. The inclusion of smaller, less multinational firms in the expanded sample may explain the differences between Jacob's results and our results. These differences demonstrate the impact of a survivorship bias on studies relying on research databases such as COMPUSTAT. The resulting differences also provide some support to the belief that there is a “learning curve” for firms operating abroad with regard to the use of transfer pricing to reduce taxes. In order to investigate whether size influences income shifting through transfer pricing policies, we separated the firms into deciles based on assets and added interaction variables between size and intrafirm transfers to the regression equations. The results of adding the size interaction variables indicates that in some instances firm size does appear to influence the use of transfer pricing policies to shift income. This research identifies the potential influence of firm size on transfer pricing policies and hopefully will encourage other researchers to consider firm size in their analysis of transfer pricing issues.