ABSTRACT

A distinctive and decisive attribute of multinational firms is the presence of intra-corporate transfers of goods and services across national boundaries. While precisely such flows have tended to make government officials uneasy - because corporate profits, and hence, various forms of government revenues or competitive objectives can be affected - there has been relatively little documentation of their magnitude, uniqueness, method of pricing, and associated firm and/or industry characteristics. 1 Furthermore, there has been a tendency to assume, without empirical support, that 'foreign' intra-corporate transfers are more problematic from a government standpoint than 'domestic' intra-corporate transfers (Shulman, 1969). This paper attempts to address these voids by examining transfer pricing data filed with the US Federal Trade Commission (FTC) for a large sample of US manufacturing firms. The findings are among the relatively few which document patterns of behaviour in the transfer pricing area.