The Oxford Handbook of International Business

By Alan M. Rugman; Thomas L. Brewer | Go to book overview

Chapter 21 Taxes, Transfer Pricing, and the Multinational Enterprise

Lorraine Eden


21.1 Introduction

I can find only one functional area in which governments have made a serious effort to reduce the conflicts or resolve the ambiguities that go with the operations of multinational enterprises. The industrial countries have managed to develop a rather extraordinary web of bilateral agreements among themselves that deal with conflicts in the application of national tax laws. Where such laws seemed to be biting twice into the same morsel of profit, governments have agreed on a division of the fare. Why governments have moved to solve the jurisdictional conflict in this field but not in others is an interesting question. Perhaps it was because, in the case of taxation, the multinational enterprises themselves had a major stake in seeing to the consummation of the necessary agreements. (Vernon 1985 : 256)

Transfer pricing—the pricing of cross-border intrafirm transactions between related parties—used to be a term known only to a few international

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