TY  - JOUR
AU  - Bradford,David F.
TI  - Addressing the Transfer-Pricing Problem in an Origin-Basis X Tax
JF  - National Bureau of Economic Research Working Paper Series
VL  - No. 9843
PY  - 2003
Y2  - July 2003
UR  - http://www.nber.org/papers/w9843
L1  - http://www.nber.org/papers/w9843.pdf
N1  - Author contact info:
David F. Bradford
Woodrow Wilson School
Princeton University
Princeton, NJ 08544-1013
Tel: 609/258-1856
Fax: 609/258-2809
E-Mail: BRADFORD@PRINCETON.EDU
AB  - In a previous paper I described how the tax design called the X Tax would facilitate an international tax system free of many of the complexities and avoidance opportunities plaguing the existing international tax regime and also have neutrality properties generally deemed desirable. A choice must, however, be made between two basic treatments of transborder business transactions --the origin and destination principles. The destination-principle approach sidesteps the need to identify arm's length terms of transborder transactions between related business entities -- the transfer-pricing problem. This serious problem remains in the origin-principle approach, which, however, presents fewer challenges of monitoring the flow of goods and services across borders, obviates what I call the  tourism problem' whereby people can reduce their taxes by consuming in a low-tax jurisdiction and, arguably most important, avoids transition effects associated with introduction of the tax and subsequent tax rate changes that occur in the destination approach. In this paper I explore possible special rules for transborder transactions between related parties in an origin-based system to eliminate the transfer-pricing problem.
ER  -