Research Article
Characteristic Variables of Multinational Enterprises in Selecting Non-Market-Based Methods in International Transfer Pricing
Published: January 1998 · Vol. 27 No. 5 · pp. 1171-1194
Full Text
Abstract
This study empirically analyzes the influence of environmental and firm-specific variables of multinational corporations on their strategic selection of non-arm's-length pricing methods in international transfer pricing decisions. The research methodology first utilized data collected through a survey of 141 multinational corporations, and to determine the independent variables representing the internal and external environmental factors of multinational corporations, 32 items were selected based on prior research and subjected to factor analysis. The five factors determined through this factor analysis were included as model variables, and two firm-specific variables—the home country of the parent company and firm size—were added to the model. A PROBIT analysis was then conducted to explain which factors influence multinational corporations' selection of international transfer pricing methods. According to the research results, tax-related factors and firm size of multinational corporations emerged as important determinants in the selection of international transfer pricing strategies, while economic factors, joint venture factors, political and social factors, and internal corporate factors of multinational corporations were found to be either unimportant or, at most, secondary determinants in international transfer pricing decisions. Furthermore, the location of the multinational corporation's parent company was found to influence international transfer pricing decisions differently, suggesting the need to clearly diagnose environmental differences across countries when addressing tax responses related to transfer pricing decisions of multinational corporations. Therefore, the results of this study are expected to be useful for practitioners at multinational corporations expanding overseas in identifying the critical variables when strategically designing international transfer pricing decisions.
