Transfer Pricing in the Decentralized Multinational Corporation

This paper considers how the multinational corporation's transfer price responds to changes in international corporate effective tax rates. It extends the decentralized decision-making analysis of transfer pricing in the context of different tax rates. It adopts and extends Bond's (1980) model of the decentralized multinational corporation that assumes centralized transfer pricing. The direction of transfer price change is as expected, while the magnitude of change is likely to be less than predicted by the Horst (1971), centralized decision-making model. The paper extends the model further by assuming negotiated transfer pricing, where the analysis is partitioned into perfect and imperfect information cases. The negotiated transfer pricing result reverts to the Horst (1971), or centralized decision-making, result, under perfect information. Under imperfect information, the centralized decision-making result obtains when top management successfully informs division general managers or it successfully implements a non-monetary reward scheme to encourage division general managers to cooperate. Under simplifying assumptions, centralized decision-making dominates decentralized decision-making, while negotiated transfer pricing weakly dominates centralized transfer pricing.

International Transfer Pricing for Goods and Intangible Asset Licenses in a Decentralized Multinational Corporation: Review and Extensions

We review and extend the core literature on international transfer price manipulation to avoid or evade taxes. Under negotiated transfer pricing with a viable bargaining structure, including performance evaluation disconnected from the transfer price, divisions voluntarily exchange accurate information to obtain firm-wide optimality, a result not dependent on restraint from exercising internal market power. For intangible licenses, a larger optimal profit shift for a given tax rate change strengthens incentives for transfer pricing abuse. In practice, an intangible's arm's length range is viewed as a guideline, a context where incentives for abuse materialize. Transfer pricing for intangibles obliges greater tax authority scrutiny.

The determinants of offshore production by Multinational Corporations (MNCs) : a comparison of Japanese and US MNCs

This study employs confidential affiliate-level panel data to improve measures of foreign affiliate activities of Japanese firms in manufacturing sectors. Combining existing data on U.S. MNCs with the Japanese data, we illustrate the pattern and determinant of their foreign affiliate sales by destination market across countries and industries for the period 1989-2005. Among our results, Japanese and U.S. MNCs are similar in the substantial growth of their foreign affiliate sales and the importance of sales to local markets. However, Japanese MNCs are distinctive from U.S. MNCs in that Japanese affiliate sales in Asia were prominently higher in host markets with lower educational attainment.

Location choice of multinational enterprises in China : comparison between Japan and Taiwan

This paper examines and compares the location choice of Japanese and Taiwanese MNEs in China. Furthermore, we investigate the relationship between location choice and firm characteristics, specifically firms' productivity. Due to Taiwan's linguistic and cultural advantages in China, it is expected that the location choice mechanics are different between Japanese and Taiwanese MNEs. As a result, our main findings are that, while the less productive Japanese firms prefer a location in an area with a larger agglomeration of Japanese affiliates or in an area closer to Japan, the more productive Taiwanese firms prefer a location in an area with a larger agglomeration of Taiwanese affiliates or in an area closer to Taiwan.

Tax differentials and inflow of foreign direct investments : evidence from foreign operations of U.S. multinational companies

This paper concerns the measurement of the impact of tax differentials across countries on inflow of Foreign Direct Investment (FDI) by using comprehensive data on the foreign operations of U.S. multinational corporations that has been collected by the Bureau of Economic Analysis (BEA), the U.S. Department of Commerce. In particular, this research focuses on examining: (1) how responsive FDI locations are to tax differentials across countries, (2) how different the tax effect on FDI inflow is between developed and developing countries, and (3) whether investment location decisions have become more or less sensitive to tax differences between countries over time ranging from the late 1990s to the early 2000s. Estimation results suggest that high rates of corporate income taxation are associated with reduced foreign assets of U.S. multinational firms in all industries by decreasing the return to foreign asset investment. Further, foreign assets of U.S. multinationals in all industries have become more responsive to non-income tax differentials across countries than to income tax differences from 1999 to 2004. Empirical estimates also indicate that foreign investment by American firms is associated with higher tax sensitivity more in developed countries than in those that are developing.

Simulating heterogeneous multinational firms

This paper develops a micro-simulation framework for multinational entry and sales activities across countries. The model is based on Eaton, Kortum, and Kramarz's (2010) quantitative trade model adapted towards multinational production. Using micro data on Japanese manufacturing firms, we first stylize the empirical regularities of multinational entry and sales activity and estimate the model's structural parameters with simulated method of moments. We then demonstrate that our adapted model is able to replicate important dimensions of the in-sample moments conditioned in our estimation strategy. Importantly, it is able to replicate activity under an economic period with a far different level of FDI barriers than was conditioned upon in our estimation sample. Overall, our research highlights the richness of the simulation framework for performing counterfactual analysis of various FDI policies.

Transport modal choice by multinational firms : firm-level evidence from Southeast Asia

We examine transport modal decision by multinational firms to shed light on the role of freight logistics in multinational activity. Using a firm-level survey in Southeast Asia, we show that foreign ownership has a significantly positive and quantitatively large impact on the likelihood that air/sea transportation is chosen relative to truck shipping. This result is robust to the shipping distance, cross-border freight, and transport infrastructure. Both foreign-owned exporters and importers also tend to use air/sea transportation. Thus, our analysis presents a new distinction between multinational and domestic firms in their decision over transport modes.

Heterogeneous multinational firms and productivity gains from falling FDI barriers

During the past decade of declining FDI barriers, small domestic firms disproportionately contracted while large multinational firms experienced a substantial growth in Japan’s manufacturing sector. This paper quantitatively assesses the impact of FDI globalization on intra-industry reallocations and aggregate productivity. We calibrate the firm-heterogeneity model of Eaton, Kortum, and Kramarz (2011) to micro-level data on Japanese multinational firms. Estimating the structural parameters of the model, we demonstrate that the model can strongly replicate the entry and sales patterns of Japanese multinationals. Counterfactual simulations show that declining FDI barriers lead to a disproportionate expansion of foreign production by more efficient firms relative to less efficient firms. A hypothetical 20% reduction in FDI barriers is found to generate a 30.7% improvement in aggregate productivity through market-share reallocation.

The determinants of the quality of Sales-Marketing Interface in a Multinational Customer Brand Focused Company: The Latin American Branches

Customer evolution and changes in consumers, determine the fact that the quality of the interface between marketing and sales may represent a true competitive advantage for the firm. Building on multidimensional theoretical and empirical models developed in Europe and on social network analysis, the organizational interface between the marketing and sales departments of a multinational high-growth company with operations in Argentina, Uruguay and Paraguay is studied. Both, attitudinal and social network measures of information exchange are used to make operational the nature and quality of the interface and its impact on performance. Results show the existence of a positive relationship of formalization, joint planning, teamwork, trust and information transfer on interface quality, as well as a positive relationship between interface quality and business performance. We conclude that efficient design and organizational management of the exchange network are essential for the successful performance of consumer goods companies that seek to develop distinctive capabilities to adapt to markets that experience vertiginous changes

A multinational SDI-based system to facilitate disaster risk management in the Andean Community

A useful strategy for improving disaster risk management is sharing spatial data across different technical organizations using shared information systems. However, the implementation of this type of system requires a large effort, so it is difficult to find fully implemented and sustainable information systems that facilitate sharing multinational spatial data about disasters, especially in developing countries. In this paper, we describe a pioneer system for sharing spatial information that we developed for the Andean Community. This system, called SIAPAD (Andean Information System for Disaster Prevention and Relief), integrates spatial information from 37 technical organizations in the Andean countries (Bolivia, Colombia, Ecuador, and Peru). SIAPAD was based on the concept of a thematic Spatial Data Infrastructure (SDI) and includes a web application, called GEORiesgo, which helps users to find relevant information with a knowledge-based system. In the paper, we describe the design and implementation of SIAPAD together with general conclusions and future directions which we learned as a result of this work.

Marketing and Sales organization in a “Brand-Focused Professional” multinational

This article tests a multidimensional model of the marketing and sales organizational interface, based on a previous one tested for European companies (Homburg et al., 2008), in a specific taxonomical configuration: a brand focused professional multinational, in three successful Latin American branches. Factor reliability and hypotheses were studied through a confirmatory factor analysis. Results show the existence of a positive relationship between formalization, joint planning, teamwork, information sharing, trust and interface quality. Interface quality and business performance show also a positive relationship. This empirical study contributes to the knowledge of the organizational enhancement of interactions in emerging markets

Insights, attitudes, and perceptions about asthma and its treatment : a multinational survey of patients from Europe and Canada

Acknowledgments Editorial assistance was provided by Ken Kauffman and Patricia Abramo, Adelphi Communications, New York, NY. This assistance was funded by Merck & Co., Inc.

Toward a successful multinational crop plant genome initiative

Plant genome research is needed as the foundation for an entirely new level of efficiency and success in the application of genetics and breeding to crop plants and products from crop plants. Genetic improvements in crop plants beyond current capabilities are needed to meet the growing world demand not only for more food, but also a greater diversity of food, higher-quality food, and safer food, produced on less land, while conserving soil, water, and genetic resources. Plant biology research, which is poised for dramatic advances, also depends fundamentally on plant genome research. The current Arabidopsis Genome Project has proved of immediate value to plant biology research, but a much greater effort is needed to ensure the full benefits of plant biology and especially plant genome research to agriculture. International cooperation is critical, both because genome projects are too large for any one country and the information forthcoming is of benefit to the world and not just the countries that do the work. Recent research on grass genomes has revealed that, because of extensive senteny and colinearity within linkage groups that make up the chromosomes, new information on the genome of one grass can be used to understand the genomes and predict the location of genes on chromosomes of the other grasses. Genome research applied to grasses as a group thereby can increase the efficiency and effectiveness of breeding for improvement of each member of this group, which includes wheat, corn, and rice, the world’s three most important sources of food.

Defining and Measuring Metrics for a Multinational Human Resources Department

Successful HR departments should support key business objectives by establishing metrics that determine the effectiveness of their processes. Functions such as recruiting, benefits, and training are processes that should have metrics. Understanding who measures what, when, and how often is the first step in measuring how much it costs to run HR. The next step is determining which processes are most critical, and then determining the metrics that fit the business needs. Slight adjustments will need to be made as business needs change, but the process for measuring outcomes should not change. This paper will focus on multinational corporations that employ at least ten thousand employees and have a ratio of one HR professional to every hundred fulltime equivalents (FTEs).