Abstract

 Transfer Pricing Strategy of the Multinational Enterprise

In this paper, I have argued the financing effects of transfer pricing from the point of view of the measures to overcome the market imperfections by multinational enterprise. Multinational enterprises usually establish the transfer pricing to maximize its global after-tax profits. But, they can only achieve profits maximization to a short term. For example, in reality, it is difficult for multinational enterprises to adjust the transfer price according to the fluctuations of exchange rate at any time. Consequently, it is thought that the purpose of the transfer pricing strategy should be the reduction of cost of capital in the long run or the improvement of financing conditions rather than the profits maximization in a short term. And, I have built a model to suggest that there are two financing effects by adjusting transfer price. The first financing effect is that the saving of global tax payment and/or exchange profits by adjusting transfer price. And, the second one is that the saving of cost of financing because of better financial conditions and get higher credit rating or stock price by first financing effect. And, in Japan, because the stock prices have a trend that is decided only on the parent company's financial statement. And, conform to Japanese commercial law, the source of dividend to stockholders is based only on the parent's profits. No matter how good condition the accounting for consolidation is, it is impossible to maintain dividend if the parent's profits fell. It is thought the stock prices factor is an incentive of transfer pricing, certainly. But, we can not overlook the above-mentioned, the rationality of saving the costs of financing by transfer pricing, either.