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022			_a00014788
040			_aMSU _bEnglish _cMSU _erda
050	0	0	_aHD30.4 ACC
100			_aMura, Alessandro _eauthor
245	1	0	_aChallenging the reliability of comparables under profit-based transfer pricing methods _ccreated by Alessandro Mura, Clive Emmanuel and Francesco Vallascas
264	1		_aAbingdon: _bRoutledge, _c2013
336			_2rdacontent _atext _btxt
337			_2rdamedia _aunmediated _bn
338			_2rdacarrier _avolume _bnc
440			_aAccounting and business research _vVolume 43, number 5
520	3		_aUnder profit-based transfer pricing methods, the selection of comparable companies is essential if detection of transfer price manipulation is to be reliable. Comparative advantage as embedded in internalisation theory argues that foreign-controlled companies (FCCs) should, in the long run, display greater profitability than domestic-controlled companies. In high-tax host countries, transfer pricing manipulation theory predicts an opposite effect on profitability. Applying a refined set of tests to a large sample of firms operating in a high-tax country such as Italy offers strong support for the internalisation prediction. Furthermore, the analysis of the interquartile range of our measure of profitability indicates that only a low percentage of FCCs would be subject to fiscal enquires, as implied by the Organisation for Economic Co-operation and Development guidelines, under the suspicious of transfer pricing manipulation. These results suggest that current comparability tests are likely to fail the identification of transfer pricing practices in countries where the comparative advantage of FCCs is particularly pronounced and question the reliability of these tests.
650			_aTransfer pricing _vReliability _xProfit-based methods
700	1		_aEmmanuel, Clive R. _eco-author
700	1		_aVallascas, Francesco _eco-author
856			_uhttps://doi.org/10.1080/00014788.2013.798581
942			_2lcc _cJA
999			_c166811 _d166811