In conventional accounting literature, ‗transfer pricing' is portrayed as a technique for optimal allocation of costs and revenues amongst divisions, subsidiaries and joint ventures within a group of related entities. Such representations of transfer pricing simultaneously acknowledge and occlude how it is deeply implicated in processes of wealth retentiveness that enable companies to avoid taxes and facilitate the flight of capital. A purely technical conception of transfer pricing calculations abstracts them from the politico-economic contexts of their development and use. The context is the modern corporation in an era of globalized trade and its relationship to state tax authorities, shareholders and other possible stakeholders. Transfer pricing practices are responsive to opportunities for determining values in ways that are consequential for enhancing private gains, and thereby contributing to relative social impoverishment, by avoiding the payment of public taxes. Evidence is provided by examining some of the transfer prices practices used by corporations to avoid taxes in developing and developed economies. Institution has argued that -transfer pricing is used by virtually every multinational corporation to shift profits at will around the globe‖ (Baker, 2005, p. 30).
KeywordsThe mobilization of transfer pricing for tax avoidance 2 , and sometimes evasion, is largely invisible to the public and is difficult and expensive for regulatory authorities to detect. There is indeed a complex game involving numerous actors -corporations, accountants, lawyers, consultants, governments, tax authorities, multinational agencies (e.g. OECD), NGOs and so on -engaged in establishing and revising the rules of the game with regard to which method(s) of calculating prices is acceptable, and also developing and detecting ways of manipulating, escaping or subverting these rules and methods. As means of enhancing divisional, segmental, product and global profits, the unimpeded use of transfer pricing matters to stock markets as earnings, dividends, share prices and return on capital are all affected. It also matters to company executives because their financial rewards are frequently linked to corporate earnings. Transfer pricing practices matter to the state because they affect the taxes 4 that it can levy upon corporate profits to finance public goods and thereby secure legitimacy.Business advisers claim that -transfer pricing continues to be, and will remain, the most important international tax issue facing MNEs‖ (Ernst & Young, 2006, p. 5 Transfer pricing is a well-established topic in accounting textbooks, but the use of transfer pricing 4 to avoid taxes and shift capital has attracted little sustained interest (Sikka et al., 2007). The bourgeoning corporate social responsibility literature is largely silent on the role of transfer pricing in tax avoidance and the flight of capital (Christensen and Murphy, 2004). A considerable body of literature draws attention to the economic theories underlying transfer pric...