Transfer Pricing and the Decision-Making Authority of the Tax Function in Multinational Companies

Abstract

The allocation of decision rights is a fundamental issue of organizational design. We study the decision-making authority and respective outcomes within firms’ transfer pricing function where tax and managerial objectives typically conflict. Exploring unique survey data on transfer pricing systems of multinational companies, we investigate the extent to which the centralization of decision-making authority at the tax department is associated with (external) tax audit conflicts and (internal) coordination conflicts. We find that disputes with local tax authorities are more likely, i.e. tax risk is higher, when the tax department has ultimate authority over transfer pricing decisions. This result is consistent with theory predicting that central tax managers focus on firm-wide objectives instead of easing local tax audits. Internal coordination, however, seems to be unaffected by the allocation of decision rights to the tax department.