Date of Conferral







Kenneth Sherman


Multinational enterprises (MNEs) engage in tax-planning strategies between their related parties that affect their profit and consequently their tax liability. Transfer pricing (TP) legislation addresses these tax planning strategies of MNEs resulting in increased tax revenues. Despite the updated 2006 TP legislation, shifting of profit and taxes is still occurring by MNEs; therefore, the implications of this legislation need to be examined. The purpose of this study was to compare the reporting of profit, before and after change in legislation, as well as to examine the cost of services mediation of the relationship between the status of the legislation and profit reported. The study's theoretical framework was a combination of economic and strategic management theories. This ex-post facto quantitative study addressed two research questions with the first examining the difference in the reporting of operating profit before and after the updated TP legislation. The second assessed how the cost of services mediates the relationship between the status of the TP legislation and the reporting of operating profits. Data collected on a sample of tax returns, representing 32 industry sectors for each of 14 years, from the Internal Revenue Service were used in applying statistical tests for answering these research questions. The results indicated that the updated TP regulations influenced MNEs for reporting greater profit than before the update as well as possibly inconsistent mediation with the proposed mediator of cost of services. These results support having TP legislation since it would increase tax revenues resulting in positive economic and social changes as well as contributing to achieving sustainable development.