Fiscal Transfer Pricing in Multinational Corporations

The scope of transfer price manipulation by multinational corporations is relatively limited, but certain problems do arise which all open economies must face. This volume is a study of the economic problems created by fiscal transfer pricing, as well as the relevance of these problems to an international and purely Canadian context. By means of extensive examination and analysis, first of the general institutional framework within which transfer price manipulation occurs, together with the opportunities and constraints presented within such a framework, the reader is shown practical results of the multinational organization’s ability successfully to manipulate transfer prices.

The authors adopt a ‘pseudo-empirical’ approach, using Canada and the United States as a case study. Transfer pricing is possible only within the context of a multinational organization, where there is no arm’s-length market present for the commodity in question. Moving from these premises to an examination of the structures of Canadian trade, the authors identify those markets in which multinationals are unimportant, those in which they are important but influenced by competitive prices, and those in which a great deal of trade takes place in goods for which other outside markets are of restricted importance. The principal finding of the analysis is that multinationals have a relatively restricted scope for transfer price manipulation but useful recommendations are made for tightening Canadian regulations and for their enforcement.