NATIONAL BUREAU OF ECONOMIC RESEARCH
NATIONAL BUREAU OF ECONOMIC RESEARCH

Jean-Thomas Bernard

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NBER Working Papers and Publications

January 1990Multinational Corporations, Transfer Prices, and Taxes: Evidence from the U.S.Petroleum Industry
with Robert Weiner
in Taxation in the Global Economy, Assaf Razin and Joel Slemrod, editors
June 1989Multinational Corporations, Transfer Prices, and Taxes: Evidence from the U.S. Petroleum Industry
with Robert J. Weiner: w3013
Economic research on transfer-pricing behavior by multinational corporadons has emphasized theoretical modeling and institutional description. This paper presents the fiit systematic empirical analysis of transfer prices, using data from the petroleum industry. On the basis of oil imported into the United States over the period 1973 - 1984, we test two propositions: i) Are prices set by integrated companies for their internal transfers different from those prevailing in arm 's-length (i.e., inter-company) trade, when other variables, such as oil quality, are controlled for? ii) Do average effective corporate income tar rates explain observed patterns of transfer pricing? Regression analysis leads to the following conclusions: i) Transfer and arm's-length prices differ significantly for...

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