Addressing the Transfer-pricing Problem in an Origin-basis X Tax
Author | : David F. Bradford |
Publisher | : |
Total Pages | : 35 |
Release | : 2003 |
ISBN-10 | : OCLC:163365096 |
ISBN-13 | : |
Rating | : 4/5 ( Downloads) |
Download or read book Addressing the Transfer-pricing Problem in an Origin-basis X Tax written by David F. Bradford and published by . This book was released on 2003 with total page 35 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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