Deterring Transfer Pricing Abuse: Changing Incentives As a Practical Alternative to a Global Tax Regime

Abstract

The Article presents information on the abuse of transfer pricing by multinational enterprises and the changes brought in the jurisdiction of the Tax Court of the U.S. for solving this abuse. The focus of the changes is to deter the enterprises from aggressive tax-avoidance behaviour and reduction of tax burden. Information on allocation of income in the lower tax countries for preventing tax evasion is also presented.

Keywords

International business enterprises, Jurisdiction, Tax evasion, Tax incidence, Allocation (Accounting), Transfer pricing, United States. Tax Court

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Authors

David A. Osborne (Washington University School of Law)

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