이전가격 결정방법이 소득이전에 미치는 영향 = The Influence of International Transfer-pricing Methods on Income Shifting

다국어 초록 (Multilingual Abstract)

In this paper, we investigate the effect of international transfer-pricing methods on income shifting. Typically, transfer pricing is determined by using one of four methods: (1) cost-based (2) market-based (3) negotiated or (4) dual. Among them, cost-based methods are regarded as providing more room for manipulation in comparison with other methods because they are determined using internal cost data available and it is not easy to determine a fair profit to add to cost. Therefore, multinational corporations that intend to shift their income from host countries to home countries or other countries are more likely to choose cost-based methods. We obtained the data about transfer-pricing methods from foreign-controlled companies in Korea and analysed whether the companies levels of income shifting were influenced by these methods. We used gross margin as a proxy for income shifting based on the assumption that if multinational corporations shift their income from host countries to other countries, it would result in a lower gross margin. The results show that the foreign-controlled companies in Korea using cost-based methods have a relatively lower gross margin. <Key words> transfer-pricing, income shifting, cost-based methods

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