The system of Transfer Pricing in a multinational

Transfer prices are used by the majority of firms worldwide when intermediate products or services are transferred within the same organization. These prices are reported as revenue for the selling entity (division, unit, department etc.) and as cost for the buying entity. Nevertheless, transfer prices lead to many disputes among managers in the same organization as transfer prices influence the performance of their entities. In cross-border transactions, transfer prices can be used by firms to reduce corporate taxes and thus, increase total firm profits. In order to fight against this firms’ practice, tax authorities require firms to establish a transfer pricing system in accordance with OECD1 Transfer Pricing Guidelines.

Sustained competitive advantage of different sized multinational corporations in rural base of the pyramid markets

This thesis explores how multinational corporations of different sizes create barriers to imitation and therefore sustain competitive advantage in rural and informal Base of the Pyramid economies. These markets require close cooperation with local partners in a dynamic environment that lacks imposable property rights and follows a different rationale than developed markets. In order to explore how competitive advantage is sustained by different sized multinational corporations at the Base of the Pyramid, the natural-resource-based view and the dynamic capabilities perspective are integrated. Based on this integration the natural-resource-based view is extended by identifying critical dynamic capabilities that are assumed to be sources of competitive advantage at the Base of the Pyramid. Further, a contrasting case study explores how the identified dynamic capabilities are protected and their competitive advantage is sustained by isolating mechanisms that create barriers to imitation for a small to medium sized and a large multinational corporation. The case study results give grounds to assume that most resource-based isolating mechanisms create barriers to imitation that are fairly high for large and established multinational corporations that operate at the rural Base of the Pyramid and have a high product and business model complexity. On the contrary, barriers to imitation were found to be lower for young and small to medium sized multinational corporations with low product and business model complexity that according to some authors represent the majority of rural Base of the Pyramid companies. Particularly for small to medium sized multinational corporations the case study finds a relationship- and transaction-based unwillingness of local partners to act opportunistically rather than a resource-based inability to imitate. By offering an explanation of sustained competitive advantage for small to medium sized multinational corporations at the rural Base of the Pyramid this thesis closes an important research gap and recommends to include institutional and transaction-based research perspectives.