Transfer pricing and multinational financial institutions : the case for replacing arm’s length price with a unitary approach

The international tax system, designed a century ago, has not kept pace with the modern multinational entity rendering it ineffective in taxing many modern businesses according to economic activity. One of those modern multinational entities is the multinational financial institution (MNFI). The recent global financial crisis provides a particularly relevant and significant example of the failure of the current system on a global scale. The modern MNFI is increasingly undertaking more globalised and complex trading operations. A primary reason for the globalisation of financial institutions is that they typically ‘follow-the-customer’ into jurisdictions where international capital and international investors are required. The International Monetary Fund (IMF) recently reported that from 1995-2009, foreign bank presence in developing countries grew by 122 per cent. The same study indicates that foreign banks have a 20 per cent market share in OECD countries and 50 per cent in emerging markets and developing countries. Hence, most significant is that fact that MNFIs are increasingly undertaking an intermediary role in developing economies where they are financing core business activities such as mining and tourism. IMF analysis also suggests that in the future, foreign bank expansion will be greatest in emerging economies. The difficulties for developing countries in applying current international tax rules, especially the current traditional transfer pricing regime, are particularly acute in relation to MNFIs, which are the biggest users of tax havens and offshore finance. This paper investigates whether a unitary taxation approach which reflects economic reality would more easily and effectively ensure that the profits of MNFIs are taxed in the jurisdictions which give rise to those profits. It has previously been argued that the uniqueness of MNFIs results in a failure of the current system to accurately allocate profits and that unitary tax as an alternative could provide a sounder allocation model for international tax purposes. This paper goes a step further, and examines the practicalities of the implementation of unitary taxation for MNFIs in terms of the key components of such a regime, along with their their implications. This paper adopts a two-step approach in considering the implications of unitary taxation as a means of improved corporate tax coordination which requires international acceptance and agreement. First, the definitional issues of the unitary MNFI are examined and second, an appropriate allocation formula for this sector is investigated. To achieve this, the paper asks first, how the financial sector should be defined for the purposes of unitary taxation and what should constitute a unitary business for that sector and second, what is the ‘best practice’ model of an allocation formula for the purposes of the apportionment of the profits of the unitary business of a financial institution.

A nation's role in addressing base erosion and profit shifting : sovereignty in relation to transfer pricing

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether or engage in both collaboration and co ordination with other nations and supranational bodies alike or maintain a unilateral stance in relation to its tax policy. This article considers a modern conceptualisation of sovereignty to argue that a move towards a more unified approach to addressing international base erosion and profit sharing may be the ultimate exercise of national fiscal sovereignty.

Investor sentiment as conditioning information in asset pricing

This paper assesses whether incorporating investor sentiment as conditioning information in asset-pricing models helps capture the impacts of the size, value, liquidity and momentum effects on risk-adjusted returns of individual stocks. We use survey sentiment measures and a composite index as proxies for investor sentiment. In our conditional framework, the size effect becomes less important in the conditional CAPM and is no longer significant in all the other models examined. Furthermore, the conditional models often capture the value, liquidity and momentum effects.

Improving information in project appraisal using hedonic pricing : a case study of marina berthing charges

Hedonic pricing techniques can be used to generate quantitative information useful to the project appraiser at various stages of the project cycle, most notably project formulation and investment appraisal. To illustrate, a hedonic pricing model is applied to marina berthing charges in England and Wales. The technique determines the relevant marina facilities that are reflected in marina rental price. The contribution of the key marina facilities is expressed in monetary terms as the contribution to cost per overall rental price per foot.

The impact of a congestion pricing exemption on the demand for new energy efficient vehicles in Stockholm

As governments seek to transition to more efficient vehicle fleets, one strategy has been to incentivize ‘green’ vehicle choice by exempting some of these vehicles from road user charges. As an example, to stimulate sales of Energy-Efficient Vehicles (EEVs) in Sweden, some of these automobiles were exempted from Stockholm’s congestion tax. In this paper the effect this policy had on the demand for new, privately-owned, exempt EEVs is assessed by first estimating a model of vehicle choice and then by applying this model to simulate vehicle alternative market shares under different policy scenarios. The database used to calibrate the model includes owner-specific demographics merged with vehicle registry data for all new private vehicles registered in Stockholm County during 2008. Characteristics of individuals with a higher propensity to purchase an exempt EEV were identified. The most significant factors included intra-cordon residency (positive), distance from home to the CBD (negative), and commuting across the cordon (positive). By calculating vehicle shares from the vehicle choice model and then comparing these estimates to a simulated scenario where the congestion tax exemption was inactive, the exemption was estimated to have substantially increased the share of newly purchased, private, exempt EEVs in Stockholm by 1.8% (+/- 0.3%; 95% C.I.) to a total share of 18.8%. This amounts to an estimated 10.7% increase in private, exempt EEV purchases during 2008 i.e. 519 privately owned, exempt EEVs.

Audit pricing and product differentiation in small private firms : evidence from Thailand

Purpose – There is limited evidence on how differences in economic environments affect the demand for and supply of auditing. Research on audit pricing has mainly focused on large client markets in developed economies; in contrast, the purpose of this paper is to focus on the small client segment in the emerging economy of Thailand which offers a choice between auditors of two different qualities. Design/methodology/approach – This paper is based on a random stratified sample of small clients in Thailand qualifying for audit exemption. The final sample consists of 1,950 firm-year observations for 2002-2006. Findings – The authors find evidence of product differentiation in the small client market, suggesting that small firms view certified public accountants as superior and pay a premium for their services. The authors also find that audit fees have a positive significant association with leverage, metropolitan location and client size. Audit risk and audit opinion are not, however, significantly associated with audit fees. Furthermore, the authors find no evidence that clients whose financial year ends in the auditors’ busy period pay significantly higher audit fees, and auditors engage in low-balling on initial engagements to attract audit clients. Research limitations/implications – The research shows the importance of exploring actual decisions regarding audit practice and audit pricing in different institutional and organizational settings. Originality/value – The paper extends the literature from developed economies and large/listed market setting to the emerging economy and small client market setting. As far as the authors are aware, this is the first paper to examine audit pricing in the small client market in an emerging economy.

Clash of the titans: Apple, Adobe, and Microsoft under fire at IT pricing inquiry

Today, an Australian parliamentary committee grilled the IT titans - Apple, Adobe, and Microsoft - on price discrimination against Australian consumers. The IT companies were evasive under questioning.

IT pricing: Copyright law, consumer rights, and competition policy. A submission to the House of Representatives Standing Committee on Infrastructure and Communications Inquiry into IT Pricing

For a hundred years, since Federation, Australian consumers have suffered the indignity and the tragedy of price discrimination. From the time of imperial publishing networks, Australia has been suffered from cultural colonialism. In respect of pricing of copyright works, Australian consumers have been gouged; ripped-off; and exploited. Digital technologies have not necessarily brought an end to such price discrimination. Australian consumers have been locked out by technological protection measures; subject to surveillance, privacy intrusions and security breaches; locked into walled gardens by digital rights management systems; and geo-blocked.

On the efficacy of Fourier series approximations for pricing European options

This paper investigates several competing procedures for computing the prices of vanilla European options, such as puts, calls and binaries, in which the underlying model has a characteristic function that is known in semi-closed form. The algorithms investigated here are the half-range Fourier cosine series, the half-range Fourier sine series and the full-range Fourier series. Their performance is assessed in simulation experiments in which an analytical solution is available and also for a simple affine model of stochastic volatility in which there is no closed-form solution. The results suggest that the half-range sine series approximation is the least effective of the three proposed algorithms. It is rather more difficult to distinguish between the performance of the halfrange cosine series and the full-range Fourier series. However there are two clear differences. First, when the interval over which the density is approximated is relatively large, the full-range Fourier series is at least as good as the half-range Fourier cosine series, and outperforms the latter in pricing out-of-the-money call options, in particular with maturities of three months or less. Second, the computational time required by the half-range Fourier cosine series is uniformly longer than that required by the full-range Fourier series for an interval of fixed length. Taken together,these two conclusions make a case for pricing options using a full-range range Fourier series as opposed to a half-range Fourier cosine series if a large number of options are to be priced in as short a time as possible.

Electricity pricing in New Zealand and the Australian State of Queensland: Accounting for the impact of sector restructuring

The electricity industries of New Zealand (NZ) and the Australian state of Queensland have undergone substantial structural and regulatory reform with the common intent to improve economic efficiency. Deregulation and privatisation have been key elements of the reform but have been approached differently by each jurisdiction. This study traces the link between structural and regulatory regimes and asset valuation, profits and, ultimately, pricing. The study finds that key drivers in recent price increases are the government-owned generation and retail sector in NZ and the government-owned distribution sector in Queensland. It is concluded that, contrary to the rationale for the imposition of regulatory controls in a nonmarket environment, the regulatory regimes appear to have contributed to higher rather than lower pricing structures.

Risk Minimizing Option Pricing in a Semi-Markov Modulated Market

We address risk minimizing option pricing in a semi-Markov modulated market where the floating interest rate depends on a finite state semi-Markov process. The growth rate and the volatility of the stock also depend on the semi-Markov process. Using the Föllmer–Schweizer decomposition we find the locally risk minimizing price for European options and the corresponding hedging strategy. We develop suitable numerical methods for computing option prices.

Creating healthy food environments in N.S.W.: A knowledge and evidence synthesis to inform advocacy and action: Food pricing

Reviews and synthesizes evidence to produce evidence-based recommendations on policy actions to improve food pricing for NSW Health

Symposium: Food pricing and affordability of ‘healthy’ versus ‘less healthy’ diets: An international approach to monitoring and surveillance

Symposium co-ordinated by The International Network for Food and Obesity/NCDs Research, Monitoring and Action Support (INFORMAS) Purpose Global monitoring of the price and affordability of foods, meals and diets is urgently needed. There are major methodological challenges in developing robust, cost-effective, standardized, and policy relevant tools, pertinent to nutrition, obesity, and diet-related non-communicable diseases and their inequalities. There is increasing pressure to take into account environmental sustainability. Changes in price differentials and affordability need to be comparable between and within countries and over time. Robust tools could provide baseline data for monitoring and evaluating structural, economic and social policies at the country/regional and household levels. INFORMAS offers one framework for consideration.

Formula apportionment and transfer pricing under oligopolistic competition

This paper demonstrates that under conditions of imperfect (oligopolistic) competition, a transition from separate accounting (SA) to formula apportionment (FA) does not eliminate the problem of profit shifting via transfer pricing. In particular, if affiliates of a multinational firm face oligopolistic competition, it is beneficial for the multinational to manipulate transfer prices for tax–saving as well as strategic reasons under both FA and SA. The analysis shows that a switch from SA rules to FA rules may actually strengthen profit shifting activities by multinationals.

Transfer pricing rules and competing governments

The literature on the regulation of multinationals' transfer prices has not considered the possibility that governments may use transfer pricing rules strategically when they compete with other governments. The present paper analyses this case and shows that, even in the absence of agency considerations, a non‐cooperative equilibrium is characterised by above‐optimal levels of effective taxation. We then derive conditions under which harmonization of transfer pricing rules lead to a Pareto improvement, and show that harmonization according to the ‘arm's length’ principle—the form of harmonization advocated by the OECD—may not be Pareto improving.