國際對替價格決定理論의 比較分析

A Study on International Transfer Pricing for Motivation

Transfer Pricing is one of the most interesting topic in accounting. It has been treated in economic field by Hirshleifer since 1956, then by Gould, and by Ronen and Mckenny. It, also, has been treated in mathmatical programming field by Samuels and by Baumol and Fabian. In addition, it has been treated in behavioral aspects thru the research of Watson and Baumler and of Swieringa and Waterhouse. International transfer pricing which is strongly related with multinational enterprise has rarely been researched except thru a few research. These research, however, treated the international transfer pricing as the management policy or management strategy to minimize tax burden. They were focused upon selecting the optimal transfer price. The optimal transfer pricing has several defects. First, generally speaking, transfer pricing is used not only for minimizing tax policy, but also for evaluating foreign subsidiary manager's performance, In many cases, minimizing tax strategy cannot work to evaluate the proper performance. Especially agency theory directed that this strategy cannot work as an motivational tool because of moral hazard problem. Secondly, even though the optimal transfer price is calculated thru the sophiscated mathmatical programming, it cannot treat the whole variables in the real world. Especially in many cases the parameters are treated as being certain, but in the real world most of them are uncertain. Thirdly, in many countries, their governments have been started to establish the regulation the international transfer price which caused the avoidance of tax and tariff. They demand the every transaction has to be done under the arm's length principle. If the arm's length principle were not satisfied, they don't accept the transfer price as being the proper one. In this study, we reviewed the optimal transfer pricing in chapter 2. In chapter 3, we pointed out that the optimal transfer price was regulated under the arm's length principle and introduced the regulation of OECD and GATT. In addition, we pointed out that it disguised the management performance. In chapter 4, the agency theory was introduced and the malfunction of the optimal transfer price was proved under the agency theory. In chapter 5, we suggested the international transfer pricing to motivate the foreign subsidiary managers thru the establishing the incentive contract which could cover the risk. We, however, didn't treat what was the proper compensation scheme for manager to be motivated. For example, this can be done thru the laboratory experiment. We postpone this research to further study.