Title
Transfer pricing practices of transnational corporations in PATA countries
Document Type
Article
Publication Date
2010
Abstract
The tax authorities of Australia, Canada, Japan and the United States formed the Pacific Association of Tax Administrators (PATA) in 1980 to combat income shifting, improve cross-border information flows, and develop conciliatory relationships among themselves. One of their specific concerns was to identify and stop the improper transfer pricing used by transnational corporations (TNCs) to facilitate income shifting and obfuscation of financial data.
The purpose of this study is to determine: (1) what PATA membership means for TNCs, and (2) whether or not transfer pricing audits have increased due to information sharing or decreased due to PATA's various transfer pricing guides. A survey of tax executives in Australian, Canadian, Japanese, and U.S. TNCs was undertaken to determine the answers to these questions, and to develop policy and procedure recommendations for both the TNCs and their respective tax authorities. Unexpected findings emerged about the relationship between transfer pricing behaviors and audit frequency, and between audit risk and advance pricing agreement status.
Language
English
DOI
https://doi.org/10.1016/j.intaccaudtax.2009.12.003
Recommended Citation
Borkowski, Susan C., "Transfer pricing practices of transnational corporations in PATA countries" (2010). Department of Accounting Faculty Work. 7.
https://digitalcommons.lasalle.edu/accounting_faculty/7
Comments
This article is the authors' final published version in Journal of International Accounting, Auditing and Taxation, Volume 19, Issue 1, 2010, Pages 35-54.
The published version is available at https://doi.org/10.1016/j.intaccaudtax.2009.12.003. Copyright © Elsevier Inc.