TY - JOUR
T1 - Transfer pricing comparables
T2 - Preferring a close neighbor over a far-away peer?
AU - Steens, Bert
AU - Roques, Thibaut
AU - Gonnet, Sébastien
AU - Beuselinck, Christof
AU - Petutschnig, Matthias
N1 - Funding Information:
We are grateful to TPED Members, two anonymous referees, and Robert Larson (editor-in-chief) for their helpful suggestions and Hugo Chary for his excellent data assistance. ☆ This research did not receive any specific grant from funding agencies in the public, commercial, or not-for-profit sectors.
Publisher Copyright:
© 2022 The Author(s)
PY - 2022/6
Y1 - 2022/6
N2 - In a globalized economy, transfer pricing estimations are key in valuing international transactions between entities of multinational corporations (MNCs), and the use of uncontrolled peer group comparison methods are widespread. In the absence of uniform guidelines on the optimal identification for comparable companies, however, it remains a concern that poor selection choices may lead to biased estimates. This may systematically bias cross-jurisdictional revenue flows. The current approach employed by tax practitioners and implicitly endorsed by several tax administrations worldwide commonly relies on comparables from neighboring countries. We employ a global sample of over 11,000 manufacturing firms located across 84 countries over the period 2012–2016. We find evidence that the risk level of the country where companies are incorporated is highly correlated with their profitability and that geographical closeness is less relevant for explaining profitability when controlling for country risk. Our findings suggest that the search for foreign comparables is better guided by country risk rather than geographic proximity and that insufficiently controlling for country-level sovereign risk biases high-risk countries’ corporate tax revenues downwards. We conclude that the accuracy of comparables is likely to benefit from expanding the scope of observations to a global level, while controlling for country risk.
AB - In a globalized economy, transfer pricing estimations are key in valuing international transactions between entities of multinational corporations (MNCs), and the use of uncontrolled peer group comparison methods are widespread. In the absence of uniform guidelines on the optimal identification for comparable companies, however, it remains a concern that poor selection choices may lead to biased estimates. This may systematically bias cross-jurisdictional revenue flows. The current approach employed by tax practitioners and implicitly endorsed by several tax administrations worldwide commonly relies on comparables from neighboring countries. We employ a global sample of over 11,000 manufacturing firms located across 84 countries over the period 2012–2016. We find evidence that the risk level of the country where companies are incorporated is highly correlated with their profitability and that geographical closeness is less relevant for explaining profitability when controlling for country risk. Our findings suggest that the search for foreign comparables is better guided by country risk rather than geographic proximity and that insufficiently controlling for country-level sovereign risk biases high-risk countries’ corporate tax revenues downwards. We conclude that the accuracy of comparables is likely to benefit from expanding the scope of observations to a global level, while controlling for country risk.
KW - Comparables
KW - Corporate tax
KW - Country risk
KW - Geographical proximity
KW - Transfer pricing
UR - http://www.scopus.com/inward/record.url?scp=85131588113&partnerID=8YFLogxK
UR - http://www.scopus.com/inward/citedby.url?scp=85131588113&partnerID=8YFLogxK
U2 - 10.1016/j.intaccaudtax.2022.100471
DO - 10.1016/j.intaccaudtax.2022.100471
M3 - Article
AN - SCOPUS:85131588113
SN - 1061-9518
VL - 47
SP - 1
EP - 18
JO - Journal of International Accounting, Auditing and Taxation
JF - Journal of International Accounting, Auditing and Taxation
M1 - 100471
ER -