Transfer pricing comparables: Preferring a close neighbor over a far-away peer?

Bert Steens*, Thibaut Roques, Sébastien Gonnet, Christof Beuselinck, Matthias Petutschnig

*Corresponding author for this work

Research output: Contribution to JournalArticleAcademicpeer-review

Abstract

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.

Original languageEnglish
Article number100471
Pages (from-to)1-18
Number of pages18
JournalJournal of International Accounting, Auditing and Taxation
Volume47
Early online date16 May 2022
DOIs
Publication statusPublished - Jun 2022

Bibliographical note

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)

Keywords

  • Comparables
  • Corporate tax
  • Country risk
  • Geographical proximity
  • Transfer pricing

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