HighlightsThis paper directly estimates the deviation in prices between those done within a multinational and those done at arm's length while controlling for firm and destination characteristics.We find significant transfer pricing behavior, with prices diverging by 11%.Transfer pricing is due primarily to tax havens, not simply low-tax countries.During our sample, transfer pricing resulted in a 1% reduction in French corporate tax revenue.
AbstractThis paper analyzes the transfer pricing of multinational firms. We propose a simple framework in which intra-firm prices may systematically deviate from arm's length prices for two motives: i) pricing to market, and ii) tax avoidance. Multinational firms may decide not to avoid taxes if the risk to be sanctioned is high compared to the tax gap. Using detailed French firm-level data on arm's length and intra-firm export prices, we find that both mechanisms are at work. The sensitivity of intra-firm prices to foreign taxes is reinforced once we control for pricing-to-market determinants. Most importantly, we find almost no evidence of tax avoidance if we disregard exports to tax havens. Back-of-theenvelope calculations suggest that tax avoidance through transfer pricing amounts to about 1% of the total corporate taxes collected by tax authorities in France. The lion's share of this loss is driven by the exports of 450 firms to ten tax havens. As such, it may be possible to achieve significant revenue increases with minimal cost by targeting enforcement.
This paper investigates the impact of transport costs on firm pricing policy. The empirical part provides new evidence on trade prices based on firm level data from France. We find that for a given product, a typical exporting firm sets higher (net of transport costs) prices toward more distant countries. This empirical regularity suggests that firms charge higher markups and/or sell more expensive quality upgraded versions of their product when facing higher transport costs. None of these two mechanisms is present in models of international trade. Even models with firm heterogeneity in terms of quality fail in explaining the firm pricing policy observed in the data. We demonstrate that, in existing models of trade, for firms to set higher markups or to upgrade the quality of their product toward more distant countries it is necessary to relax the mill pricing assumption and to use per unit rather than iceberg transport costs. This finding is critical since, in trade models, the structure of transport costs affects the microeconomic behavior of exporting firms but also the composition of export flows and the size of gains from trade.
PEO was conducted on Al by applying a pulsed bipolar current. The role of the cathodic polarization on the appearance of micro-discharges (MDs) and on the subsequent formation of the PEO oxide layers is investigated. Various ratios of the charge quantity RCQ = Q p / Q n (defined as the anodic Q p to cathodic Q n charge quantity ratio over one current pulse period) in the range [0.5 ; 6.0] were selected by changing the waveform parameters of the cathodic current while keeping the waveform of the anodic current unchanged. Results show that the appearance of MDs is delayed with respect to the rising edge of the anodic current; this delay strongly depends on both the processing time and the applied cathodic charge quantity. It is also evidenced that shorter delays promoted by high RCQ (RCQ > 1) values are associated with stronger MDs (large size and long life) that have detrimental effects on the formed PEO oxide layers. The thicker and the more compact oxide layer morphology is achieved with the intermediate RCQ (RCQ = 0.9) for which the delay of the MDs appearance is high and the MDs softer. Low RCQ (RCQ < 0.9) results in an earlier extinction of the MDs as the process goes on, which leads to poorly oxidized metal. A mechanism of charge accumulation taking place at the oxide / electrolyte interface and arising before the occurrence of dielectric breakdown is proposed to explain the ignition of MDs during pulsed bipolar PEO of aluminium. A close examination of the voltage-time response which can be adequately simulated with an equivalent RC circuit evidences the capacitive behaviour of the oxide layer and therefore confirms this proposed mechanism of charge accumulation.
International audienceMicro-Raman spectroscopy was used to investigate the main deformation micromechanisms of isotactic polypropylene uniaxially stretched at constant temperature (T = 30 °C) under a constant true strain rate (inline image = 5.10−3 s−1). To accurate measurements namely to be free of the recovering phenomenon which causes in most of the cases interference during post-mortem analysis, we introduced a new experimental setup combining a Raman spectrometer with a tensile machine piloted by the VidéoTraction™ system. Microstructure is described by essential parameters such as the crystallinity index, the macromolecular orientation both in the crystalline and the amorphous phase, and distribution of the internal stress at the chemical bonds scale. For each, a well-tried Raman spectral criterion was used. Cross-checking of these results, obtained with a minimum of tensile tests, allows a more complete understanding of the deformation micromechanisms of semi-crystalline polymer
We investigate whether plants inside and outside geographic clusters differ in their resilience to adverse economic shocks. To this end, we develop a bottom-up procedure to delimit clusters using Canadian geo-coded plant-level data. Focussing on the textile and clothing industries and exploiting the series of dramatic changes faced by that sector between 2001 and 2013, we find no evidence that plants in clusters are more resilient than plants outside clusters: they are neither less likely to die nor more likely to adapt by switching their main line of business. However, conditional on switching, plants in urbanized clusters are more likely to transition to services.
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