Comparing cross-cultural regulatory styles and processes in dealing with transfer pricing
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Sakurai, Yuka
Australian National University. Centre for Tax System Integrity
Australian Taxation Office
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Centre for Tax System Integrity (CTSI), Research School of Social Sciences, The Australian National University
Australian Taxation Office
Australian Taxation Office
Abstract
ltinational corporations (MNCs) and between tax administrations in relation to transfer
pricing. This paper examines cross-national differences in both management and
regulatory styles between the US, the UK and Japan in relation to transfer pricing and
evaluates Australia’s transfer pricing regulatory strategy. Data were based on semistructured
interviews conducted in July 2000 to September 2001 with tax managers
working for MNCs, tax advisors employed by the Big Five accounting firms, and revenue
authorities from Australia, Japan, the UK and the US. The results suggest that crossnational
differences in management styles do exist between Japanese MNCs and their
Western counterparts. However, harmonisation of management styles is occurring. The
results suggest that the different regulatory styles employed by US, UK and Japanese tax
administrations have both merits and shortcomings for ensuring compliance with transfer
pricing rules. The implications of this study are discussed in a global regulatory context.
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