Tax-motivated transfer mispricing in South Africa: Direct evidence using transaction data

• 成果类型: Article
• 署名作者: Wier, Ludvig
• 署名单位: University of California System; University of California Berkeley
• 刊物名称: JOURNAL OF PUBLIC ECONOMICS
• ISSN/ISSBN: 0047-2727
• DOI: 10.1016/j.jpubeco.2020.104153
• 发表日期: 2020
• 关键词: tax; international taxation; Profit shifting; multinational firms; Developing countries

摘要

This paper provides the first direct systematic evidence of profit shifting through transfer mispricing in a developing country. Using South African transaction-level customs data, I directly test for transfer price deviations from arm's-length pricing. I find that multinational firms in South Africa manipulate transfer prices in order to shift taxable profits to low-tax countries. The estimated tax loss relating to imported goods alone is 0.5% of corporate tax payments. My estimates do not support the common belief that transfer mispricing in South Africa is more severe than in advanced economies. I find that an OECD-recommended reform had no long-term impact on transfer mispricing but argue that the method used in this paper provides a cost-efficient way to curb transfer mispricing. (C) 2020 UNU-WIDER. Published by Elsevier B.V.