다국적기업의 국제이전가격과세협상에 관한 연구

As globalization of multi-national enterprises is gaining momentum, it is likely that international transfer pricing conflicts take place among MNCs and taxing authorities. This paper tried to check the possibility of deriving the simultaneous optimality among the parties. From the perspectives of information structure, international transfer pricing can be interpreted as Larger-Lerner information structure, which has such solutions as an alternating offers, prolonged disagreement, refinements of sequential equilibrium in bargaining and strategic delay. In this sense, both signal sender(MNC) and signal receiver(tax authorities) have noises under incomplete information. As results, true reporting does not guarantee risk free reporting when MNC tries to avoid international transfer pricing conflicts. MNC will make contingent decision of signaling information depending upon the informational capability of tax authorities. As game theoretic view, international transfer pricing can be modeled by the combination of signaling game and arbitration game. Mathematical solution tells that MNC's best bet is not to conceal the information but to reveal the information strategically positively to verify evidence of normal price prior to initiation of international transfer pricing conflicts.