Fuzzy Profit Shifting: A Model for Optimal Tax-induced Transfer Pricing with Fuzzy Arm's Length Parameter

Alex A.T. Rathke

MPRA Paper from University Library of Munich, Germany

Abstract: This paper proposes a model of optimal tax-induced transfer pricing with a fuzzy arm's length parameter. Fuzzy numbers provide a suitable structure for modelling the ambiguity that is intrinsic to the arm's length parameter. For the usual conditions regarding the anti-shifting mechanisms, the optimal transfer price becomes a maximising a-cut of the fuzzy arm's length parameter. Nonetheless, we show that it is profitable for firms to choose any maximising transfer price if the probability of tax audit is sufficiently low, even if the chosen price is considered a completely non-arm's length price by tax authorities. In this case, we derive the necessary and sufficient conditions to prevent this extreme shifting strategy.

Keywords: fuzzy profit shifting; transfer pricing; tax evasion; tax enforcement; tax penalty. (search for similar items in EconPapers)
JEL-codes: F23 H26 K34 (search for similar items in EconPapers)
Date: 2019-01-12
New Economics Papers: this item is included in nep-acc, nep-law and nep-pub
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