Title: Minority Ownership, Deferral, Perverse Intrafirm Trade and Tariffs
Author: Kant, Chander
Author Affiliation: Seton Hall U
Source: International Economic Journal, Spring 1995, v. 9, no. 1, pp. 19-37
Publication Date: Spring 1995
Abstract: When the foreign subsidiary has minority local ownership and the MNF engages in transfer pricing, its intrafirm exports are always from the country with the higher marginal cost. Further, permitting deferral from home taxation of non-repatriated foreign profits changes the nature of intrafirm trade from efficient to perverse even when the foreign subsidiary is fully-owned by the MNF. Intrafirm trade differs significantly from that between unrelated buyers and sellers, and tariffs on such trade (when it is perverse) can restore global production efficiency.

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