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Transfer Pricing, Earnings

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Transfer Pricing, Earnings

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Muhammad fidaul Islam

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The current issue and full text archive of this journal is available on Emerald Insight at:

www.emeraldinsight.com/1359-0790.htm

Transfer
Transfer pricing, earnings pricing
management and tax avoidance of
ﬁrms in Ghana
Mohammed Amidu, William Coffie and Philomina Acquah 235
Business School, University of Ghana, Legon, Ghana

Abstract
Purpose – This paper aims to investigate how transfer pricing (TP) and earnings management affect tax
avoidance of firms in Ghana.
Design/methodology/approach – The authors use a panel data set from 2008 to 2015 to further shed
light on transfer pricing-tax avoidance nexus by examining the complex interaction of three key variables:
transfer pricing, earnings management and tax avoidance.
Findings – The results show that almost all the sample firms have engaged in some form of transfer pricing
strategies and the manipulation of earnings to avoid tax during 2008-2015. There is evidence to suggest that non-
financial multinational corporations manipulate more earnings than the financial firms while financial firms also
use more TP than non-financial firms. The overall results suggest that the sensitivity of tax avoidance to transfer
pricing decreases as firms increase their earnings management. By extension, these results have important policy
implication for policymakers in assessing the effectiveness of tax laws relating to transfer pricing.
Originality/value – The authors investigate how transfer pricing and earnings management affect the
avoidance of firms operating in Ghana.
Keywords Tax avoidance, Earnings management, Developing country, Transfer pricing
Paper type Research paper

1. Introduction
Globalization allows flow of the financial resources from developed countries into the
emergent economies (Tomedi and Schreiber, 2014). The rising pace of globalization has
driven the concept of nations and states due to flexibility of transfer pricing and its role in
avoiding taxes by redirecting public revenue to shareholders (Sikka and Willmott, 2010).
Globalization has come to eliminate the limitations of territorial jurisdiction of corporations
and has paved an easier way of establishing subsidiaries, affiliate joint ventures, special
purpose entities and trusts in jurisdictions with favourable conditions to benefit from low
tax havens. Accordingly, Chang and Lin (2010) show that multinational corporations
(MNCs) derive various benefits from international trade, including trade expansion, job
opportunities, transfer of technology, flow of international market information, frequent
promotion of industries, technical research and development, economic growth and
increased taxes. Therefore, the MNCs attempt to embrace these benefits with the ultimate
goal of maximizing global profit and minimizing their global taxes by locating their
affiliates in countries with very low or zero tax rate. In an attempt to achieve the goal of
global profit maximization and tax minimization, the multinational firms have resorted to
several tax avoidance mechanisms which have led to revenue losses of both tax haven Journal of Financial Crime
countries and developing countries attempting to operate as tax haven with low tax rate. Vol. 26 No. 1, 2019
pp. 235-259
Research on international tax avoidance practices suggest that MNCs avoid international © Emerald Publishing Limited
1359-0790
taxes by means of transfer pricing manipulation, thin capitalization, tax haven utilization, DOI 10.1108/JFC-10-2017-0091
JFC payment of intangibles, income shifting and financing structure of affiliate (Jacob, 1996;
26,1 Chang and Lin, 2010; Taylor and Richardson, 2012; Henn, 2013; Brock and Pogge, 2014).
More so, most of these studies reveal that transfer pricing manipulation is the main
avoidance mechanism used by these corporations in an attempt to achieve their goal of
global profit maximization and tax minimization objectives (Gravelle, 2009; Pendse, 2012;
Janský et al., 2013)[1]. The manipulation of this transfer pricing occurs when a company in
236 an attempt to either purchase or sell to an affiliated entity under-price or over-price the
goods or service for the reason that the two companies are located in a variable different tax
jurisdictions (Clausing, 2003; Dyreng and Lindsey, 2009; Slemrod and Wilson, 2009; Cristea
and Nguyen, 2013; Brock and Pogge, 2014). This manipulation then offers an opportunity to
the MNCs to relocate profit from countries that these profits originated to countries with
lower tax rates. This effect is frequently observed in the developing economies as a result of
their human capital inadequacies to deal with the complex nature of transactions
undertaken within affiliated entities and inadequate policies to eliminate such practices.
Also, transfer pricing has the propensity to reduce the entitlement of domestic shareholders
and employees due to the under reporting of profit.
Strands of literature show that tax avoidance behaviour serves as motivation for
earnings management (Graham et al., 2012; Wang and Chen, 2012). Studies on earnings
management have professed that devices such as changes in accounting procedures, taking
a bath, income maximization and income smoothing are the major instruments that
managers use in managing earnings (Healy, 1985). However, the literature on earnings
management stipulates that in an attempt to manage earnings, firms structure their
transaction in a way that create differences in the taxable profit and the accounting income
(Hanlon and Heitzman, 2010). These empirical studies have outlined that managers manage
earnings so as to report lower profit to pay less tax (Dhaliwal et al., 2004; Desai and
Dharmapala, 2006; Desai and Dharmapala, 2009). These avoidance mechanisms result in
loss of revenue which hinders the ability of the government to undertake its social and
economic responsibilities (Sikka and Willmott, 2010; Otusanya, 2011; Taylor and
Richardson, 2012). According to Desai and Dharmapala (2009), tax avoidance mechanisms
give room for opportunistic managers to pursue self-seeking objectives and manage
earnings in ways that provide benefits to managers and that do not benefit shareholders.
Thus, managers managing earnings are more likely to insulate themselves by avoiding
more taxes as avoidance provides them shield from shareholder scrutiny. Again, minimized
tax payment leaves excess “after tax” cash flow that can either be distributed as extra
dividends or invested in profitable projects. Although various studies have analysed the
variables of interest and have established relationships among them, these relationships
have been examined independently in most cases. Prior studies have failed to exploit how
the relationship between transfer pricing and earnings management can jointly influence
tax avoidance behaviour of MNCs. Therefore, the study seeks to examine how transfer
pricing and earnings management influence tax avoidance of MNCs operating in developing
countries. It is analysed within the Ghanaian context.
The contribution of this study is in two folds: first of all, it examines the prevalence of
transfer pricing and earnings management as it pertains to MNCs operating the developing
countries. This serves as a response to the calls by prior research for more research on
earnings manipulation and transfer pricing in different economic settings (Healy and
Wahlen, 1999). Second, the study examines the effect of the interaction of the transfer
pricing and earnings management on tax avoidance.
The rest of the paper is organized as fellows. Section 2 reviews relevant literature on
transfer pricing, earnings management and tax avoidance. Section 3 discusses the research
methodology, the measurement of key variables used in the study, as well as data. Section 4 Transfer
discusses the regression results and sensitivity tests, and finally, Section 5 provides the pricing
conclusions and policy implications.

2. Literature review
This section reviews the literature on the subject matter. We begin with the theoretical
principles underlying transfer pricing, earnings management and tax avoidance. We then
discuss the empirical literature on the variables that affect the relationship of interest.
237

2.1 Theoretical overview

We discuss two major theories that underpin our study, i.e. the agency theory (Ross, 1973;
Jensen and Meckling, 1976) and the stakeholder theory (Freeman, 1984). The agency theory
was initiated by Ross (1973) from the economic perspective. Ross economic theory of agency
concerning the problem faced by the principal was one of choosing a compensation system
that will induce an agent to exhibit behaviour consistent with the principal’s preference in a
contractual relationship between an agent and his principal. This theory was later extended
by Jensen and Meckling (1976). In the research paper of Jensen and Meckling (1976), an
agency relationship exist where one party (the principal) engages another party (an agent)
and delegate work and some decision making authority to the agent who then accomplishes
such work on behalf of the principal. The theory postulates that when both parties are utility
maximizers then the agent will refuse to take actions in line with the principal’s interest.
This brings about the conflict of interest between insider manager and the outside
stockholders of public corporations. Hence, the theory postulates that instituting a
compensation contract will help to align the interest of managers with that of their
shareholders. This compensation contact is based on accounting earnings. Therefore, the
theory posits that accounting numbers play a central role in mitigating the conflict of
interest between managers and stockholders (Jensen and Meckling, 1976).
The theory of agency attempts to define such association using an allegory of contract
(Jensen and Meckling, 1976). The theory explains that an organization is a nexus of
contracts having a set of contractual relationship with providers of funds, suppliers,
customers, creditors and so on. As stock ownership is far and remote from control,
shareholders are unable to manage their entities on their own and hence the shareholders
hire managers to manage the firm on their behalf. Therefore, managers should take
decisions that maximize shareholders value. Nevertheless, this dominant view has not been
without criticisms. Freeman (1984/2004) argued that managers should pay attention to all
constituencies that can affect the firm. Thus managers’ decisions should not consider only
the interest of shareholders but include all other stakeholders such as the employees,
customers, creditors and the community (Freeman, 1999/2005). Freeman (1984) further
indicated that the other stakeholders play a very vital role in the life of the organization and
hence their interest should be given equal relevance as given to the shareholders.
Corporate managers have the responsibility to run the affairs of the corporation and
therefore have thorough information about the corporation. If such information is not made
available to the stakeholders would result in information asymmetry. Information
asymmetry occurs when managers have information that stakeholders do not have any
knowledge of (Ross, 1973). Such privilege information held by managers increases their
ability to exploit benefits from other stakeholders leading to the agency problem (Jensen and
Meckling, 1976; Donaldson and Davis, 1991; Healy and Palepu, 2001). According to
Eisenhardt (1989), the agency theory focuses on resolving two main agency problems that
are likely to occur in the agency relationship. The first problem befalls when the goal of the
JFC agent differs substantially from that of the principal. The second problem also arises when
26,1 the principal finds it difficult or expensive to confirm the actual performance of the agent. In
our study, we identify the shareholder and the tax authority to suffer from lack of adequate
information about the transfer pricing activities and earnings management practices of
the firm. To prevent such problems from occurring, the shareholder and the tax authority
have to incur some cost to limit the conflicting interest which exist between them and the
238 managers of the firm (see, Jensen and Meckling,1976; Crutchley and Hansen, 1989).
Earnings management is defined as the active manipulation of accounting information to
create an altered impression of the firm’s financial performance, as measured by its
earnings. Earnings are managed through income minimization, taking a bath, income
maximization and income smoothing (Healy, 1985). However, Donaldson and Davis (1991)
documented that the practice of earnings smoothing with the aim of meeting market
expectation and earnings target does not create value for the firm but rather results in
decisions that destroy firm value. The aim of every company is to maximize its stock market
value and hence managers who are hired to manage the affairs of the firm on behalf of
shareholders are responsible for achieving that aim. Therefore, the decisions and actions of
managers should result in value enhancement (Jensen and Meckling, 1976; Fama and Jensen,
1983; Jensen, 2002). Tax avoidance is value enhancing, however, managers refuse to
undertake such activity as a result of the conflicting interest that exists between managers
and shareholders as stipulated by the theory, hence managers only engage in avoidance
activities when they stand to gain some private benefit from engaging in such activities.
Therefore, managers in charge of taking avoidance activities consider only those decisions
that yield them some personal advantage. This then supports the assumption underpinning
the agency theory that human beings are self-interested characters acting reasonably to
maximize their own private gains (Donaldson and Davis, 1991: Crutchley and Hansen, 1989;
Jensen, 2005). Having recognized that one of the value maximization activities is tax
avoidance, the opportunistic behaviour of managers induce them to engage in avoidance
practices with the intension of diverting proceeds into their own pocket.

2.2 Empirical review

This section seeks to review the empirical literature of the study.
2.2.1 Transfer pricing and tax avoidance review. The growing rate of globalization with
the benefits of foreign direct investment has necessitated cross boarder and international
trade among business corporations (Abdallah and Maghradi, 2009; Chang and Lin, 2010).
However, when MNCs are deciding whether to invest at home or abroad to embrace such
benefits, the level of tariffs, tax laws and regulations are taken into consideration to achieve
the goal of global tax minimization and profit maximization by embracing the benefits of
low tax rate and tax free polices of the host country (Bartelsman and Beetsma, 2003;
Borkowski, 2010; Olibe and Rezaee, 2011; Muhammadi and Ahmed, 2016).
To achieve the global profit maximization and the tax minimization objectives, MNCs
have resorted to several tax avoidance mechanisms as a means for shifting taxable income
from high tax jurisdiction to low tax jurisdiction to reduce their corporate tax liabilities.
These mechanisms include transfer pricing, tine capitalization, tax haven utilization,
financing structure of affiliates (debt financing), contract manufacturing and the strategic
location of asset and overhead cost (Grubert and Mutti, 1991; Choi and Day, 1998;
Bartelsman and Beetsma, 2003; Dharmapala, 2008; Gravelle, 2009; Pendse, 2012; Janský
et al., 2013; Rossing and Rohde, 2014). Notwithstanding, it has been identified in the extant
literature that out of the numerous avoidance practices, transfer pricing is the main
mechanism that multinational firms use for their profit shifting practices which result in tax
avoidance (Grubert and Mutti, 1991; Choi and Day, 1998; Dharmapala, 2008; Dyreng and Transfer
Lindsey, 2009; Slemrod and Wilson, 2009; Taylor and Richardson, 2012; Cristea and pricing
Nguyen, 2013; Janský et al., 2013; Brock and Pogge, 2014; Muhammadi and Ahmed, 2016).
In line with the identification of TP as the main international tax avoidance mechanism,
the literature has examined the role of TP and has stated that TP is used for resource
allocation and tax avoidance (Sikka and Willmott, 2010), is used to achieve higher divisional
profit if managerial compensation is based on such profit and also used to shift income
(Borkowski, 2010), is a financial management mechanism that allows MNCs to move funds 239
internationally (Rossing, 2013; Chan et al., 2015), is used to obtain goal congruence, assist in
evaluating subsidiaries performance, to maximize profit and to minimize taxes (Clausing,
2009; Chang and Lin, 2010) and is a means by which the actions or parts of the organization
are integrated and differentiated and to assess their individual performance (Cools et al.,
2008; Rossing and Rohde, 2014).
The literature has also discussed in details some factors that affect the choice of a
particular transfer pricing method. These factors influence managers to choose a particular
TP method at a particular point in time as against the others. Including the numerous
factors are enterprise overall operating profit, host country’s subsidiary’s interest and host
country’s demand for maintaining appropriate cash flows (Tang, 2016), demographic and
behavioural variables (Borkowski, 2010), tax regulation (Rossing and Rohde, 2014) and
differences in transfer pricing regulation of the respective countries (Borkowski, 1997).
However, the literature has group these factors into two main categories namely external
and internal factors.
The Ghana Transfer Pricing Regulations 2012 (LI 2188) and the Organization for
Economic Cooperation and Development (OECD) have indicated that for the purpose of tax
consequences, related party transactions should be based on the arm’s length principle. The
arm’s length principle states that transactions between related parties should be carried out
as if those parties are unrelated. In line with the arm’s length principle, the regulation
requires MNCs to evaluate their intra-firm transaction using the arm’s length principle in
line with the following transfer pricing methods; the comparable uncontrolled price methods
(CUPM), the resale price method (RPM), cost plus method (CPM), transactional net margin
(TNM) method and profit split method (PSM).
2.2.2 Earnings management. Earnings management occurs when managers use
judgment in financial reporting and in structuring transactions to alter financial reports to
either mislead some stakeholders about the underlying economic performance of the
company or to influence contractual outcomes that depend on reported accounting numbers
(Healy and Wahlen, 1999). Literature on earnings management suggests that earnings
management occurs when managers have the desire to achieve an earnings target. The
literature concludes that management of earnings actually results in recording more profit
in one accounting period as against other accounting periods. Studies on why firms or
managers manage earnings include that of Jones (1991), Healy (1985), Healy and Wahlen
(1999), Beneish (2001), Bergstresser and Philippon (2004), Nagata (2013) and Yang et al.
(2016). These authors have indicated that managers manage earnings to increase their
compensation and job security; to present higher profit to hide the deterioration of
performance; to benefit from import relief, to window-dress financial statement prior to
public security offerings; to avoid the payment of corporate taxes; to avoid violating lending
contract; to meet analysts and investors earnings expectations and maintain reputation; to
reduce regulatory cost or increase regulatory benefits; and for the purpose of making initial
public offerings. Aside these underlying motives which drive managers to undertake
earnings manipulation activities, prior studies have also outlined the various devices or
JFC instruments which are used for the earnings management. These include; changes in
26,1 accounting procedures, taking a bath, income minimization, income maximization and
income smoothing.
2.2.3 Earnings management and tax avoidance. Literature on earnings management and
tax avoidance has not received much attention. However, the little empirical studies have
documented that tax avoidance serves as motivation for earnings management. These
240 studies specifically outline that managers manage earnings so as to report lower profit to
pay less tax. For example, in assessing the level at which Special Payment Account tax
policy encourages private companies in Portugal to engage in earnings management.
Marques et al. (2011) considered 6,652 firms from 2001 to 2002. Their finding suggested that
the desire to minimize taxes induce managers to manipulate earnings. Desai and
Dharmapala (2006) examined the relationship between incentive compensation, governance
structures and corporate tax avoidance. They used a simple model of managerial behaviour
for a very large sample of companies from 1993 to 2002 and showed that equity based
incentives and tax avoidance associate negatively. Their result indicated that the negative
relationship applies only to firms with weaker shareholder rights and minor intuitional
ownership. A review of tax research conducted by Hanlon and Heitzman (2010) stated that
in managing earnings firms structure their transaction in a way that create differences in the
taxable profit and the accounting income. He further indicated that managers use three
related tax items to manage earnings. The items are the valuation allowance, the tax
contingency reserve and the amount of foreign earnings designated as permanently
reinvested. Dhaliwal et al. (2004) investigated whether companies use income tax expense to
manipulate earnings and documented that tax expense indeed offers an opportunity for
managers to achieve earnings target. The study used the GAAP ERT information as proxy
for tax avoidance. Scott stated that the main reason for managing earnings is income
taxation. Additionally, Frank et al. (2009) found that managers who engage in taxable
profits and financial profits manipulation simultaneously manage their book income
upwards and also manipulate downwards their taxable profit in the same accounting year.

3. Methodology
This section seeks to address the source of data collection, measurement of estimation
variables and the empirical method.

3.1 Data source

The study draws its sample from both financial and non-financial MNCs. The data were
generated from the audited annual reports of the companies selected for the study. The audited
Annual reports of sampled manufacturing, petroleum, oil and gas and the service companies
were downloaded in soft copy format from their official websites. However, the soft copies of
some annual reports of the above-mentioned companies downloaded online did not contain the
notes to the accounts, which contain vital variables such as, the breakdown of the total tax
expense, tax payable, depreciation/amortization and the related party transactions used to
construct the transfer pricing index. As a result, hard copies of audited annual reports were also
obtained directly from headquarters of specific companies whose annual reports were
unavailable both online and the Registrar General Department.
Using annual reports to examine the abuses of transfer pricing techniques and earnings
management practices from 2008 to 2015, the study exploits the panel data techniques to
provide insight on the effects of transfer pricing aggressiveness and earnings management
practices on tax avoidance among the Ghanaian multinational firms. Panel data estimation
appears to provide more convincing results than the classical time series and cross sectional
analysis as it exploits the advantages of time series and cross-sectional data and, at the same Transfer
time, corrects the weakness of the latter two estimation techniques mentioned. It also helps pricing
to control for omitted variables and firm specific effects and also allows for both long and
short run effects thereby overcoming the shortcomings of the cross sectional and time series
estimation technique (Stock and Watson, 2001).

3.2 Variable measurement

Tax avoidance is broadly defined as the reduction of explicit taxes (Hanlon and
241
Heitzman, 2010, p. 137). Yorke et al. (2016), and Taylor and Richardson (2012), also define
tax avoidance as the difference between statutory tax rate (STR) and effective tax rate
(ETR). A resultant positive figure means tax savings which is an indication of tax
avoidance and a negative figure implies extra tax liability which the firm has to pay.
Therefore, tax savings would always be higher if the difference between ETR and STR is
wider. The ETR information is used due to its numerous advantages, which include easy
accessibility to data and data alteration impossibilities, and finally, the ETR inherently
reflects the permanent book-tax differences and all other statutory adjustments made
(Frank, Lynch, and Rego, 2009). However, the disadvantage associated with the use of the
accounting tax expense is that the measurement includes both the current and the
deferred tax expenses, where the latter may have been estimated from various
adjustments made to the deferred tax component (Hanlon, 2005). According to Hanlon
and Heitzman (2010), ETR is defined as the total income tax expense per the pre-tax
accounting. Taylor and Richardson (2012) and Noor and Fadzillah (2010) in their
respective studies computed the ETR as the total corporate tax expense divided by net
profit before tax. However, Yorke et al. (2016) contested this definition of ETR and argue
that the definition by Hanlon and Heitzman (2010), only seek to imply that tax planning is
just about minimizing the tax burden. They then argue that tax avoidance goes beyond
the minimization of tax burden but also seek to postpone the payment of taxes. With this
argument, Yorke et al. (2016) modified the numerator by deducting the deferred taxes
from the total tax expense. This modification was done to cater for the deferment
objective of tax planning. The study then employs the ETR information to proxy for the
measurement of tax avoidance. Following Yorke et al. (2016), the study measures ETR as
total corporate tax expense minus deferred tax expense and divide the result by Net profit
before corporate tax. With regard to the statutory rate, adjustment is required for all
reliefs and rebates applicable to the firm in question. As these reliefs and the rebates have
the likelihood of reducing the general statutory tax rate, it is necessary for the needed
adjustment to be done to arrive at the actual difference between the STR and the ETR to
enhance the validity of the result.
Different mechanisms have been used as a proxy for transfer pricing, including
prices charged on intra-firm transactions, Clausing (2003). Exporters price charge for
related entities in arm’s length transaction Bernard et al. (2006), differences in tax rate
between countries Desai and Dharmapala (2006), absence of immediate market to
determine the value of intangibles assets (Muhammadi and Ahmed, 2016). We pull out
three factors from the above existing research to construct a five item index as a proxy
to measure transfer pricing aggressiveness (TP) of the selected firms or to measure the
level at which the selected firms are likely to manipulate their international transfer
prices. In line with the use and application of corporate governance and disclosure
related indexes in previous research, the higher (lower) the overall score for TP, the
higher (lower) is the level of transfer pricing aggressiveness or the level of possibility of
transfer pricing manipulation. The index includes:
JFC having a subsidiary or a sibling subsidiary located in a tax haven jurisdiction;
26,1 transacting with the subsidiary or a sibling subsidiary located in a tax haven
jurisdiction for the financial year under consideration;
having a parent, a subsidiary or a sibling subsidiary located in a country with a
different tax rate other than a tax haven jurisdiction;
transacting with the related party located in a country with a different tax rate for
242 the financial year under review; and
payment of royalties associated with intangible assets between related parties for
the financial year under review.

Each of the item is scored 1 if presents and 0 otherwise. A total score of ﬁve is an indication
of a higher transfer pricing manipulation and a score of 0 indicates that the ﬁrm does not
manipulate its transfer prices. Transfer pricing is projected to relate positively with tax
avoidance.
Earnings management is measured in line with prior studies. These study used the
discretionary accrual proxy as a measure of earnings management (Jones, 1991; Dechow
et al., 1995; Rusmin, 2010; Marques et al., 2011; Nagata, 2013). The above studies also discuss
how the total accrual is decomposed into discretionary and non-discretionary components.
The total accrual is then estimated as;

TACit ¼ ðDCAit DCashit ÞðDCLit DLTDit DITPit ÞDPAit (1)

Here, TACit is the total accrual for firm i in time period t; DCAit is the change in current
assets for firm i in time period t1 to t; DCashit is the change in cash balance for firm i in
time period t1 to t; DCLit is the change in current liabilities for firm i in time period t-1 to t;
DLTDit is the change in long-term debt included in current liabilities for firm i in time period
t1 to t; DITPit is the change in income tax payable for firm i in time period t1 to t; and
DPAit is the depreciation and amortization expense for firm i in time period t1 to t. The
non-discretionary and discretionary accruals are the constituents of the total accrual. The
non-discretionary accrual depends on the firm’s level of activity while the discretionary
accruals reflect the subjective accounting choices made by managers. Thus managers
exercise their discretion over accounting methods and estimate and over the timing to
recognized accruals. Hence, the study adopts the discretionary portion of the total accruals
to proxy for earnings management. This study employs the modified Jones model which
according to Dechow et al. (1995) is the most powerful test of earnings management. The
total accruals are then regressed on gross property, plant and equipment and the changes in
revenue adjusted for changes in receivables. This is done in line with (Yang et al., 2008;
Rusmin, 2010; Liu et al., 2014; Amidu et al., 2016).

TACit 1 DREVit DRECit PPEit
¼ a0 þ b1 þ b2 þ « it (2)
TAit1 TAit1 TAit1 TAit1

Here, TACit is the total accrual for firm i in year t; TAit1 is total asset for firm i at the end of
t1; DREVit is change in net sales for firm i between years t1 and t; DRECit is the change
in receivables for firm i between years t1 and t; PPEit is the gross property plant and
equipment for firm i in year t and « it is the error term. The normal accrual NACit is removed
from equation (2) leaving the residual portion which is the discretionary accruals DCAit (i.e.
TACit - NACit). The discretionary accruals DACit for firm i at year t is the absolute value of
the residual from the above estimation model. Earnings management is expected to relate Transfer
positively with tax avoidance. pricing
To measure earnings management for the financial firms, the study proxy for earnings
management using the discretionary loan loss provision (DLLP) in line with earlier
empirical studies of Beaver and Engel (1996), Ahmed et al. (1998), Cornett et al. (2006),
Adams et al. (2009) and Amidu and Ransome (2015). These studies have described how the
loan loss allowance (reserve) and the loan loss provision have been used for earnings
management by the financial firms. Following the above authors, the current studies uses
243
the loan loss provision information to measure banks earnings management. The loan loss
provision is a combination of the non-discretionary loan loss provision and the discretionary
loan loss provision. Hence, to obtain the discretionary loan loss provision which according to
literature is the best measure of earnings management in the financial institutions, a two
stage approach is used. The first step estimates the normal loan loss provision by regressing
the LLP on the loan loss allowance (LLA), net charge off (CHGOFF), growth in loans
(GLOAN), change in loans outstanding (DLOAN), total loans (LOANS), non-performing
loans (DNPA), earnings before taxes and profit (EBTP) and year dummies
(YEARDUMMY). Additionally, LLA and CHGOFF are scaled by average loans, LLP scaled
by total loans whiles DLOAN, LOANS and EBTP are scaled by total assets. Year dummies
are introduced to control for the effect of technological changes (Amidu and Ransome, 2015;
Adams et al., 2009). This estimated figure is the normal loan loss provision. According to the
above authors, this non-discretionary loan loss provision is that portion of the loan loss
provision that brings the loan loss allowance to an acceptable level.
The second step is to deduct the estimated LLP from the actual LLP to arrive at the
discretionary LLP. Hence, the discretionary loan loss provision (DLLP) is the difference
between the actual loan loss provision (LLP) and the non-discretionary loan loss provision-
NDLLP (based on the coefficient from the first stage regression) which is presented as
DLLP = LLP – NDLLP. The literature stipulates that bank managers manipulate reported
earnings through the discretionary loan loss provision to achieve an earnings target. The
expected LLP is then estimated as;

LLPit ¼ b0 þ b1 LLAit þ b2 CHGOFFit þ b3 GLOANit þ b4 DLOANSit

þ b5 LOANSit þ b6 DNPAit þ b7 EBTPit þ g YEARRDUMMYit þ « it (3)

Here, LLPit is the actual loan loss provision scaled by total loans for bank i in period t, LLAit
is the loan loss allowance scaled by average loans of a bank i in period t, CHGOFFit is the net
charge off scaled by average loans of bank i in period t, GLOANit is the growth in loans of
bank i in period t, DLOANit is the change in total loans outstanding scaled by total assets of
bank i in period t, LOANSit is the loan portfolio scaled by total assets of bank i in period t,
DNPAit is a dummy variable representing one if the value for non-performing loan is
missing and zero if otherwise, EBTPit is earnings before taxes and profit scaled by total
assets of bank i in period t and YEARDUMMYit is a year dummy taking care of
technological changes. The residual from equation (3).3 is the discretionary loan loss
provision.
We use a number of additional control variables which prior studies have shown to affect
the relationship among transfer pricing, earnings management and tax avoidance. The
logarithm of total assets is used as a proxy for firm size. Leverage is total debt scaled by total
assets. Firm performance (ROA) is the ratio of firm profit before tax to total assets. Asset
tangibility measures the physical property of the firm and is used as asset structure. Firm’s
JFC growth potential is measured as the difference between current year’s and previous year’s
26,1 revenue over the previous year’s revenue. Lai (2009) indicated that firms with increased
growth opportunities have less incentive to report discretionary accruals especially when
they experienced increased monitoring. Firm liquidity (LIQ) is measured as current assets
over current liabilities. Liquidity is expected to positively relate to tax avoidance. Age
measures the number of years the firm has been in existence and is used as a proxy for
244 experience.

4. Empirical method
Our empirical method conditions corporate tax avoidance on transfer pricing and earnings
management. Taking guidance from this and controlling for other variables, we model
corporate tax avoidance as a function of transfer pricing and earnings management. Guided
by our objective, we use three separate econometric models as follows:

CTAit ¼ a0 þ b1 TPit þ b2 SIZEit þ b3 LEVit þ b4 ROAit þ b5 GPit þ b6 TANGit

þ b7 LIQit þ b8 AGEit þ « it (4)

CTAit ¼ a0 þ b1 EMit þ b2 SIZEit þ b3 LEVit þ b4 ROAit þ b5 GPit þ b6 TANGit

þ b7 LIQit þ b8 AGEit þ « it (5)

CTAit ¼ a0 þ b1 TPit þ b2 EMit þ b3 ðTPit EMit Þ þ b4 LEVit þ b5 ROAit

þ b6 GPit þ b7 TANGit þ b8 LIQit þ b9 AGEit þ « it (6)

Here, CTAit is the level of tax avoidance of firm i in period t. TPit is the transfer pricing
index of the firm based on the sum of five different transfer pricing items divided by
five of firm i in period t. EMit is the earnings management proxy of firm i in period t.
(TPit * EMit) is the interaction between transfer pricing and earnings management of
firm i in period t. LEVit is the leverage of firm i in period t. ROAit is the performance of
firm i in period t. GPit is the growth potential of firm i in period t. TANGit is the asset
tangibility of firm i in period t. LIQit is the liquidity of firm i in period t. AGEit is age of
firm i in period t. a is the constant term. b ’s are the parameter vectors and « it is the
error term.

4.1 Estimation strategy

To identify which of the estimation technique to be used, the Hausman’s test was
executed where the null hypothesis indicates that the random model is suitable and the
alternative hypothesis stated that the fixed effect model is appropriate. As depicted by
the Hausman’s test where [ x 2 (9) = 5.02 with p-value = 0.8325], we fail to reject the null
hypothesis. Therefore, the result recommended the use of the random effect model. The
study in attaining its objective of investigating the impact of transfer pricing on tax
avoidance and the impact of earnings management on tax avoidance among the
Ghanaian multinational firms uses the random model to establish the existence of this
relationship. Firstly, the study analyses the relationship between transfer pricing and
tax avoidance, it further examine the relationship between earnings management and
tax avoidance, and finally investigate the sensitivity of transfer pricing and earnings Transfer
management on tax avoidance. pricing
5. Data analysis and interpretation of result
5.1 Descriptive statistics
Table I presents the summary statistics on the variables used to attain the objectives of the
study covering periods between 2008 and 2015 in Ghana. 245
Table I presents the summarized details of the variables used in this study non-financial
multinational firms in Ghana from 2008 to 2015 by reporting the mean, maximum,
minimum and standard deviation. Corporate tax avoidance (CTA) was used as an outcome
variable. Hence, on the average, 5.95 per cent of non-financial MN firms in Ghana engage in
tax avoidance. It is observed that some of the firms recorded minimum and maximum of
213.86 and 77.53 per cent, respectively. This is an indication that avoidance varies quite
greatly across the sampled non-financial MN firms. Transfer pricing is on the average 53.49
per cent which the firm with the maximum transfer pricing recorded 80 per cent
manipulation of transfer prices for tax avoidance. Again, earnings management measured
as the discretionary component of total accrual is 28.21 per cent on the average. However, it
is evident that a non-financial MN firm in a particular year recorded a maximum earnings
management of 89.17 per cent implying that such firm is more aggressive in earnings
manipulation. Return on Asset (ROA) which is a measure of a firms’ profit potentials is
averagely 11.19 per cent, while some banks recorded minimum and maximum return on
asset of 11.82 and 39.47 per cent, respectively. This is an indication that profitability
varies quite moderately across the non-financial MN firms. Leverage is about 15 per cent on
the average. More so, asset tangibility, which measures the use of property plant and
equipment, is averagely 45.54 per cent. This implies that non-financial MN firms in Ghana
on the average use about 45.54 per cent of their total assets as property plant and equipment.

Variable Obs Mean SD Min Max

CTA 82 0.0595 0.3317 2.1386 0.7753

TP 83 0.5349 0.1254 0.4000 0.8000
EM 75 0.2821 0.1586 0.0422 0.8917
ROA 87 0.1119 0.1169 0.1182 0.3947
LEV 82 0.1483 0.2115 0.0026 0.9159
TANG 93 0.4554 0.2502 0.0615 0.9657
GP 74 0.1676 0.2239 0.5122 0.7770
LIQ 93 0.2845 0.6188 2.6485 0.9572
SIZE 93 119.8229 191.1709 0.0703 993.6
AGE 117 49.0769 24.2182 5 90

Notes: CTA is corporate tax avoidance measured as the difference between statutory tax rate and effective
tax rate; TP is transfer pricing index of the firm based on the sum of five different transfer pricing items
divided by five. EM is earnings management estimated as the difference between total accrual and non-
discretionary accrual. ROA is return on assets measured as earnings before interest and taxes deflated by
total asset. LEV is leverage estimated as total debt scaled by total asset. TANG is asset tangibility Table I.
measured as non-current asset scaled by total assets. GP is growth potential computed as year on year Variables’ summary
growth in sales. LIQ is liquidity estimated as current assets over current liabilities. SIZE is firm size
measured as the natural logarithm of total assets and AGE is firm age measured as the difference between statistics (non-
the year in which the firm commenced operation and the year under which the financial statement is financial
considered multinational firms)
JFC It is also observed that, a firm in year had its property plant and equipment peaking to 91
26,1 per cent of total asset.
Sale growth is on the average 16.76 per cent indicating that non-financial MN firms in
Ghana averagely increases sales by 16.76 per cent. This is an indication of poor sales growth
among the sample firms. However, it is observed that a particular firm in one year recorded
a maximum value of 77.7 per cent. Liquidity is on the average 28.45 per cent implying that
246 the firms in this category on the average can convert 28.45 per cent current asset into cash
when the need arises. A standard deviation of 61.88 per cent, minimum of 264.85 per cent
and maximum of 95.72 per cent indicate a higher level of disparity among the firms level of
liquidity. Firm size which measures the amount of total asset a firm has is averagely ¢120m.
A standard deviation of ¢191m reveals a higher variation among the sample firms with
respect to their total assets. Firm age is on the average 49 years. A standard deviation of
24.2182 indicates a high disparity in the sizes of the sampled firms. The study used the
Shapiro-Wilk (SW) Test (Table AI) to check the distribution of the variables around their
mean. The SW test reported that the variables were normally distributed around their mean.
Table II presents the summary statistics for all the variables used in this study for the
financial multinational firms. The summary statistics cover mean, standard deviation,
minimum and maximum values of all the variables. From the summary statistics table,
corporate tax avoidance is on the average 8.73 per cent. However, a maximum of 62.7 per
cent indicates that the samples multinational (MN) financial firms are highly involved in
avoidance activities. Transfer pricing is on the 47.53 per cent implying that almost 48 per
cent of the firms in this group engage in transfer pricing abuses. It is also observed that a
firm in a year recorded a maximum value of 80 per cent which depicts that some of the firms
in this group engage massively in transfer pricing manipulation. Earnings management
which measures earnings manipulation is averagely 6.05per cent. A recorded maximum
value of 92 per cent denotes aggressive earnings manipulation of some firms in this group.
Return on Asset (ROA) which is a measure of a banks’ profit potentials is averagely 3.8 per

Variable Obs Mean SD Min Max

CTA 137 0.0873 0.1123 0.0005 0.6527

TP 154 0.4753 0.1411 0.2000 0.8000
EM (LLP) 94 0.0605 0.1084 0.0009 0.9182
ROA 141 0.0380 0.1348 0.5954 0.7089
LEV 139 0.4855 0.2516 0.0008 0.9285
TANG 145 0.0540 0.0679 0.0007 0.4759
GP 101 0.2703 0.3586 0.9613 0.9366
LIQ 140 0.5781 0.0829 0.1583 0.6493
SIZE 146 498.9177 756.1859 0.6349 4113.812
AGE 101 27.07921 35.04588 1 119

5.2 Pearson correlation analysis

This section reports the correlation matrix between the various variables that are able to
explain the variation in corporate tax avoidance from literature. The table mainly exhibits
the Pearson’s correlation matrix which serves as a test for the collinearity of each variable
compared with the other variables needed to achieve the set objectives. In this paper, we set
a threshold of 0.8 for the Pearson’s correlation to be considered as the existence of high
collinearity between a variable and other variables. Hence, the results presented in Table III
show no evidence of multicollinearity. The magnitude of the relationship is determined by
the absolute value while the sign indicates the direction of the relationship. The upper right

Financial multinational firms

CTA TP EM ROA LEV TANG GP LIQ1 SIZE AGE

CTA 1 0.0614 0.0003 0.3019 0.043 0.0276 0.1505 0.2582 0.003 0.1241
TP 0.0328 1 0.0476 0.2404 0.016 0.0437 0.0604 0.0675 0.0059 0.1633
EM 0.1742 0.2367 1 0.0262 0.0077 0.0253 0.1349 0.0035 0.1304 0.0515
ROA 0.0765 0.3068 0.057 1 0.1158 0.2878 0.0438 0.199 0.0431 0.0556
LEV 0.1151 0.1667 0.3355 0.3652 1 0.0277 0.3612 0.0056 0.053 0.0678
TANG 0.2499 0.253 0.4855 0.1285 0.3498 1 0.0103 0.6881 0.2156 0.1363
GP 0.2804 0.1593 0.0429 0.2176 0.0669 0.1498 1 0.0507 0.24 0.0883
LIQ 0.0381 0.0444 0.4997 0.1061 0.4263 0.4456 0.0994 1 0.0691 0.0673
SIZE 0.1029 0.1252 0.0408 0.1126 0.3536 0.1021 0.0501 0.1255 1 0.4515
AGE 0.1059 0.0905 0.1671 0.1208 0.4942 0.216 0.216 0.1692 0.1546 1
Non-ﬁnancial multinational ﬁrms

Notes: CTA is corporate tax avoidance measured as the difference between statutory tax rate and effective
tax rate; TP is transfer pricing index of the firm based on the sum of five different transfer pricing items
divided by five. EM is earnings management estimated as the difference between total accrual and non-
discretionary accrual. ROA is return on assets measured as earnings before interest and taxes deflated by
total asset. LEV is leverage estimated as total debt scaled by total asset. TANG is asset tangibility Table III.
measured as non-current asset scaled by total assets. GP is growth potential computed as year on year Correlation matrix
growth in sales. LIQ is liquidity estimated as current assets over current liabilities. SIZE is firm size
measured as the natural logarithm of total assets and AGE is firm age measured as the difference between (for financial and
the year in which the firm commenced operation and the year under which the financial statement is non-financial
considered multinational firms)
JFC hand provide correlation matrix for financial multinational firms while the bottom left hand
26,1 show correlation for the non-financial multinational firms.
The correlation results show that EM, is as expected positively correlated with tax
avoidance. This suggest that more earnings manipulation result in more avoidance
activities. This result is not different from that of previous studies (Desai and Dharmapala,
2009; Amidu et al.2016). However, the other interest variable TP, correlate negatively with
248 tax avoidance which contradicts the findings of earlier studies. The control variables are
also positively correlated with the dependent variable except ROA, LIQ and AGE. The
positive correlation between LEV, TANG, GP and CTA reveals that highly leverage non-
financial firms with more physical assets and have growth potentials are highly involved in
avoidance activities. ROA, LIQ and AGE correlate negatively with tax avoidance implying
that profitable firms with more years of existence and are highly liquid have less incentive
to engage in avoidance activities. With respect to the financial firms, the dependent variable
(CTA) is positively correlated with the key variables of interest (TP and EM).This result is
at par with the result of other studies (Dhaliwal et al., 2004; Taylor and Richardson, 2012)
and consistent with the view that transfer pricing manipulation and earnings manipulation
facilitate tax avoidance. For the control variables, LEV and AGE correlate positively with
tax avoidance which suggests that highly leverage financial firms with more years of
existence engage more in tax avoidance. ROA, TANG and GP had negative correlation with
tax avoidance which implies that highly profitable financial firms with more physical assets
and have the potential to grow are less attractive to avoidance activities. Finally, LIQ and
SIZE correlate negatively with tax avoidance suggesting that financial firms with more
assets and are highly liquid have less scope to avoid payment of taxes.

5.3 Impact of transfer pricing on tax avoidance

This section presents the regression estimation result on the impact of transfer pricing on
tax avoidance. The study used tax avoidance (the difference between statutory tax rate and
effective tax rate) as dependent variable explained by the independent and the control
variables. The independent variable is transfer pricing (TP) and the control variables
include performance (ROA), leverage (LEV), asset tangibility (TANG), growth potential
(GP), liquidity (LIQ) and natural log of total assets (SIZE). Notwithstanding, only the
variable of interest and other significant variables are discussed.
The results of the study as presented in Table IV show a positive relationship between
transfer pricing and tax avoidance for both firm groups and the combined sample. A
coefficient of 0.037 for non-financial firms and 0.074 for financial firms indicate that
financial firms avoid more taxes through the manipulation of transfer prices than the non-
financial firms. We also observed from the coefficient of the combined sample that when
MNCs increase their transfer pricing manipulation by 100 per cent they will end up avoiding
taxes by 4.54 per cent. This suggest that MNCs avoid taxes through the manipulation of
transfer prices. This finding is consistent with existing empirical studies of Bartelsman and
Beetsma (2003), Sikka and Willmott (2010); Taylor and Richardson (2012); Janský et al.
(2013), who documented that transfer pricing manipulation facilitates tax avoidance.
For the control variables, the regression result shows a direct relationship between asset
tangibility (TANG) and tax avoidance (CTA). More so, the result indicated that both non-
financial and financial firms avoid taxes through the use of property plant and equipment.
For the entire sample, the result depicts that a unit increase in asset tangibility leads to
0.6154 units increase in tax avoidance which implies that as MNCs use more of property
plant and equipment (PPE), they end up charging more depreciation which is deducted
before the taxable income is obtained. This means that MNCs avoid taxes through the use of
Sample Non-Financial Financial Combined
Transfer
pricing
Constant 0.3336 (0.2719) 0.0297 (0.5209) 0.2063 (0.6392)
TP 0.0374 (0.0423) 0.0738 (0.0752) 0.04329 (0.1389)
ROA 0.1403 (0.3456) 0.0016 (0.0027) 0.0014 (0.0035)
TANG 0.3531** (0.1303) 0.7426** (0.0268) 0.6154*** (0.0731)
LIQ 0.2345 (0.0175) 00 0.0000*** (0)
SIZE 0.0236 (0.0292) 0.111 (0.0387) 0.0043 (0.0777) 249
R2 0.0741 0.0038 0.0044
Pro > F 0.000 0.000 0.000
No. of Obs. 81 136 217

PPE. Thus, when the tax rate is applied the tax liability generated become small implying
that majority of the tax liability has been take out as depreciation. This finding is interesting
as asset tangibility is statistically significant at 1 per cent and 5 per cent across all the
sample categories. However, the finding contradicts that of Yorke, et al. (2016) who found a
negative insignificant relationship. For the financial firms TANG recorded a negative
significant relationship with CTA. This could mean that the financial firms may be avoiding
taxes but not through the use of PPE. It is also observed that though, liquidity was not
statistically significant for both non-financial and financial companies, it was statistically
significant for the entire sample.

5.4 The eﬀect of earnings management on tax avoidance

This section shows the regression estimate results on the impact of earnings management
on tax avoidance for only non-financial firms. The study used tax avoidance as an outcome
variable explained by an independent variable and other control variables. The independent
variable is earnings management (EM) and the control variables include return on asset
(ROA), leverage, asset tangibility (TANG), growth potential (GP), liquidity (LIQ), natural log
of total assets (SIZE) and firm age (AGE). However, only the variable of interest and other
significant variables are discussed.
From the regression result in Table V, earnings management (EM) is positively related to
tax avoidance (CTA) for both financial and non-financial firms. The positive relationship
depicts that the firms avoid taxes through the manipulation of earnings. This finding
confirms existing studies of (Dhaliwal et al., 2004; Desai and Dharmapala, 2009; Amidu
et al.2016; Yorke et al., 2016). The findings also support the assumption underpinning the
agency theory that individuals are self-seeking actors acting to maximize their own personal
economic gains. The agency relationship between owners and managers requires that the
latter take decisions that maximize the interest of the former. However, the conflict of
interest between shareholders and managers induces managers such that those delegated to
take tax decisions take decisions that reflect their private ambitions to the detriment of
JFC Sample Non-Financial Financial
26,1
Constant 0.0159 (0.2893) 2.0911*** (0.3998)
EM 0.6734 (0.8508) 0.0800** (0.0341)
ROA 0.3143 (0.3247) 1.7607*** (0.4741)
LEV 0.3800*** (0.1339) 0.0608 (0.089)
TANG 0.8468* (0.4671) 2.3863*** (0.5596)
250 GP 0.6039*** (0.2191) 0.0065 (0.0416)
LIQ 0.2904 -0.4406 1.4867*** (0.3319)
SIZE 0.0002 (0.0282) 0.0015 (0.035)
AGE 1.0680** (0.4652) 0.0004** (0.0003)
R2 0.1819 0.5898
Pro > F 0.0000 0.0000
No. of Obs. 71 61

shareholders. This relationship is highly significant for the financial firms under 1 per cent
significance level with a coefficient of 0.08 as against a coefficient of 0.67 for the non-
financial firms implying that non-financial firms engage more in earnings manipulation
than the financial firms.
With regards to the control variables, return on asset (ROA) is negatively related to tax
avoidance for both firm categories which depicts that higher profitable firms avoid less tax.
Notwithstanding, the relationship is statistically significant for only financial firms under 1
per cent significance level. With a coefficient of 0.3143 and 1.7607, we found that highly
profitable non-financial firms are less attractive to avoidance activities than profitable
financial firms. Our results however, contradict the findings of prior research of Dechow
et al. (1995), Kothari et al. (2005) and Yang et al., 2008 that firms with higher performance
manipulate more of their earnings to avoid taxes. However, the above studies found a
positive relationship between ROA and CTA with the focus on only non-financial firms.
Therefore, the relationship between ROA and CTA for the non-financial firms contract the
above findings and at the same time statistically insignificant. For the financial firms, the
relationship is negatively and statistically significant which confirms the findings that
profitable banks are more in the public eye and are also more scrutinized by analyst and
hence are less likely to engage in avoidance activities.
From the regression result, LEV shows a negative statistically significant relationship
with tax avoidance under 1 per cent significance level for non-financial firms. The
relationship was also negative for financial firms but statistically insignificant. This result
contradicts the findings of previous studies that highly leverage firms engage more in tax
avoidance (Rusmin, 2010 and Amidu et al.2016). The negative significant relationship for the
non-financials firms could be intuitively explain to mean that the firms could be avoiding
taxes alright but the medium for their avoidance is not debt financing. Asset tangibility
(TANG) is positive and significantly associated with tax avoidance under 10 per cent Transfer
significance level for the non-financial firms. TANG, however, is negative and highly pricing
significant with tax avoidance for the financial firms. Intuitively, the positive significant
relationship for the non-financials could be explain to mean that companies that use more
non-current assets are expected to avoid more taxes because the depreciation charge reduces
the taxable profit.
Again, the result reveals that growth potential (GP) is positively and significantly related
to tax avoidance under 1 per cent significance level for the non-financial firms which is
251
contradictory to the study expectation that firms with increased growth opportunities are
more likely to report less discretionary accruals when they experience increased monitoring.
Hence, such monitoring provide them with less incentive to avoid taxes (Cornett et al., 2006;
Leventis and Dimitropoulos, 2012). Additionally, the result depicts a negative relationship
between liquidity (LIQ) and tax avoidance (CTA) for both firm categories. This relationship
is statistically significant at 1 per cent significant level for the financial firms. In line with
expectation, the negative significant relationship confirms that banks by nature of operation
are highly liquid and the intention is not for avoidance purposes. Finally, AGE is positively
and significantly at 5 per cent significance level with tax avoidance for both firm categories.
The findings suggest firms that have existed for more years avoid more taxes as they
become more experience to avoidance techniques. The coefficient of 1.0680 and 0.0003
indicate that non-financial firms that have existed for more years avoid more taxes than the
comparative aged financial firms.

5.5 The sensitivity of transfer pricing and earnings management on tax avoidance
The result on the third objective, investigating the sensitivity of transfer pricing and
earnings management on tax avoidance is presented in this section. The study employs tax
avoidance as a dependent variable explained by the independent and the control variables.
The independent variables include the interaction term between transfer pricing and
earnings management (TP*EM), transfer pricing (TP) and earnings management (EM)
while the control variables comprise return on asset (ROA), leverage (LEV), asset tangibility
(TANG), growth potential (GP), liquidity (LIQ) and natural log of total assets (SIZE). The
section also discusses only the variables of interest and other significant variables.
Table VI projects the regression result on the sensitivity of transfer pricing and earnings
management on tax avoidance. The result in this table suggest that the presence of the
interactive term (TP*EM) does not influence the direction of the relationship between
earnings management (EM) and tax avoidance (CTA) for both firm groups. However, the
coefficient of EM for both firm categories in Table VI with the interactive term as compared
to the coefficient in Table V without the interactive term indicates that the sample firms
engage more in earnings manipulation which result in higher avoidance with the presence of
the interactive term.
Also, the study found transfer pricing to relate positively and significantly with tax
avoidance for both firm groups with the introduction of the interactive term. This
relationship though was positive but insignificant in Table IV for both firm categories. This
indicates that the interactive term strengthens the relationship between TP and CTA.
Similar to the findings of EM, the study found that the coefficient for TP for both firm
groups in Table VI with the interactive term is higher than the coefficient of TP in Table IV
without the interactive term. This finding also suggests that both firm groups become more
aggressive to transfer pricing abuses which lead to higher tax avoidance with the
introduction of the interaction between TP and EM.
JFC Sample Non-Financial Financial
26,1
Constant 0.8662 (0.6216) 0.8299* (0.6631)
TP 0.2004* (0.1069) 0.1454*** (0.0425)
ROA 0.2278 (0.4153 2.1413*** (0.3939)
EM 0.8514 (0.6081 0.4077*** (0.1295)
TP * EM 0.6551* (0.4332) 1.6497*** (0.5616)
252 LEV 0.3115** (0.1589) 0.1002 (0.0842)
TANG 0.8956** (0.4252) 1.3941* (0.8051)
GP 0.5830*** (0.2287) 0.0008 (0.0351)
LIQ 0.3158 (0.4601) 0.6558 (0.5581)
SIZE 0.0238 (0.0393) 0.0305 (0.0357)
AGE 0.0004 (0.0017) 0.0006* (0.0004)
R2 0.2012 0.6914
Pro > F 0.0000 0.0000
No. of Obs. 71 61

With the introduction of interactive term, both relationships which were not significant in
Tables IV and V all became significant in Table VI. However, the interactive term itself is
negative and highly significant for both firm groups. These findings indicate that the two
independent variables can comfortably be used in the same model. It further depicts that the
two independent variables are separate determinant of tax avoidance. This is evidenced by the
negative coefficient recorded by the interaction term. Thus, if the interaction term had recorded
a positive coefficient, it would have meant that transfer pricing and earnings management tell
the same story and for that matter one has to be dropped from the model but in this case where
the interactive term is negative it implies that the two independent variables are not perfectly
correlated and are independent such that each of them can explain a variation in the dependent
variable. Again, the finding denotes that transfer pricing does not override on earnings
management and vice versa. This findings contribute to knowledge and reveal to literature
another determinant of international tax avoidance which is earnings management. From the
international tax avoidance literature, mechanisms such as transfer pricing, profit shifting, thin
capitalization, tax haven utilization and the financing structure of affiliate have been identified
as determinant of international tax avoidance.
In addition, a TP coefficient of 0.2004 for the non-financial firms and a coefficient of
0.1454 for the financial MN firms indicate that non-financial MN firms manipulate their
transfer prices more than the financial MN firms. More so, a coefficient of 0.8514 for EM
for the non-financial MN firms to a coefficient of 0.4077 for the financial MN firms also
depicts that the non-financial firms engage in more manipulative activities than the financial
firms. These findings could be attributed to the fact that banks are in general more regulated
and more closely monitored institutions by regulators and hence, have less incentive to
engage in manipulative activities.
Also, for the control variables, ROA is negatively related to tax avoidance for both firm Transfer
groups. However, for the financial MN firms the relationship is statistically significant under 1 pricing
per cent significant level. This result suggests that profitable banks are less attractive to tax
avoidance because they experience increased monitoring from regulators and analysts. LEV is
inversely and significantly related to tax avoidance for non-financial MN firms. This
contradicts the findings of existing literature that more leverage firms avoid more taxes
(Rusmin, 2010). Again, the findings depict that TANG is significant and associates positively
with tax avoidance for the MN non-financial firms indicating that these firms avoid more taxes 253
through the use of property, plant and equipment with its related depreciation which takes
majority of the profit after tax to the expense account as depreciation. For the financial MN,
TANG recorded a negative and significant relationship with tax avoidance. Additionally, the
result projected that GP is positively related to tax avoidance for non-financial MN firms.
Finally, AGE is positive and significant for only financial MN firms.

6. Conclusion
The study investigates the relationship between transfer pricing, earnings management and
tax avoidance. The study draws its sample of 40 firms from both non-financial and financial
multinational firms listed on Ghana Stock Exchange, as well as the non-listed multinational
firms. To achieve the overall objective of the study, the panel regression approach
specifically, the random fixed effect model was developed. To establish the existence of this
relationship, the study first examines the relationship between transfer pricing and tax
avoidance. It further analyses the relationship between earnings management and tax
avoidance and finally investigates the sensitivity of transfer pricing and earnings
management on tax avoidance.
The results suggest that Ghanaian multinational firms use both transfer pricing and
earnings manipulative activities to aggressively reduce their corporate tax liabilities.
Specifically, the study finds that the use of transfer pricing (TP) abuses and earnings
manipulation (EM) are positively related to corporate tax avoidance (CTA). More so, based
on the degrees of the regression coefficient, financial MN firms engage more in transfer
pricing manipulation than non-financial MN firms whiles the latter were found to be
aggressive in earnings manipulation than the former. The study also finds the interaction
between TP and EM to have no influence on the direction of the relationship between TP
and CTA and between EM and CTA for both firm groups. Notwithstanding, the magnitude
and the significance of the regression coefficient suggest that the presence of the interactive
term induce managers of both firm groups to become more aggressive to the manipulation
of TP and EM. The results revealed a negative and significant relationship between the
interactive term and tax avoidance. Hence, this result suggests that TP does not override
EM and that both are independent that could explain their individual variation in tax
avoidance. Further, the study finds corporate tax avoidance to relate positively and
significantly with asset tangibility, sales growth and age whiles at the same time, it relate
negatively and significantly with leverage. The result in the descriptive statistics indicates
that the sample firms in both groups are not highly leveraged and this could explain the
negative relationship between leverage and avoidance that the firms could be avoiding taxes
through other mediums other than debt financing. For the financial MN firms the result
suggests that corporate tax avoidance associate negatively and significantly with
profitability, asset tangibility and liquidity. This suggests that because the banks are
closely monitored and have more public eye they are less attractive to avoidance activities.
This study brings into existence two policy implications: First and foremost, it contributes
to existing literature on the implication of earnings manipulation on corporate tax avoidance
JFC with evidence from multinational firms in Ghana. Finally, the study also reveals the implication
26,1 of transfer pricing manipulation on tax revenue. This study is timely as it places value on the
report from the Tax Justice Network Africa, 2017 that the government of Ghana lost an amount
of GHC 2bn from transfer pricing abuses from the extractive sector. Hence, it was identified
that there are a lot of loop holes in the Ghanaian transfer pricing regulation which the
multinationals exploit to their advantage resulting in tax revenue losses to the state. Therefore,
254 the study recommends that the transfer pricing unit of GRA should equip its personnel through
effective training and at the same time institute effective strategies such that the MNCs would
submit a transfer pricing documentation for each intra firm trade that takes place between the
related parties. The documentation should outline the jurisdiction for the parties involved, the
tax rate applicable for each jurisdiction and estimate the difference in the tax rate, methodology
used and a justification for that method, a justification for the price charge and provide
comparative analysis for which such price was charged. The study further recommends that
submission of the documentation should not be done on yearly or quarterly or monthly basis
but rather for each intra firm transaction that takes place. This will help to keep track of every
intra firm trade and the acceptable price to be charged irrespective of the related parties’
jurisdiction.

Note
1. Transfer pricing is said to be the medium by which Multinational Companies (MNCs) arrive at a
price for goods and services that are traded within the related entities located in variably
different tax jurisdictions (OCED 2014). Therefore, the taxable profits that are generated in each
of the country the MNCs operate are extremely affected by these international transfer prices set
by the multinationals.

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Working Paper.
Appendix Transfer
pricing
Variable Obs. W V Z Prob > z

CTA 82 0.66271 23.626 6.939 0.00000

EM 81 0.73997 18.031 6.341 0.00000
TP 83 0.96714 2.324 1.852 0.03202 259
ROA 92 0.97485 1.937 1.460 0.07210
TPEM 79 0.84770 10.347 5.116 0.00000
LEV 92 0.53788 35.597 7.888 0.00000
TANG 93 0.93517 5.039 3.573 0.00018 Table AI.
GP 74 0.95327 3.009 2.403 0.00812 Shapiro-Wilk Test
LIQ 80 0.77207 15.645 6.026 0.00000 for Normality (non-
SIZE 92 0.93020 5.377 3.714 0.00000 ﬁnancials)

Corresponding author
William Coﬃe can be contacted at: wcoﬃ[email protected]

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Transfer Pricing, Earnings

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Transfer Pricing, Earnings

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The current issue and full text archive of this journal is available on Emerald Insight at:

2.1 Theoretical overview

2.2 Empirical review

3.1 Data source

3.2 Variable measurement

TACit ¼ ðDCAit DCashit ÞðDCLit DLTDit DITPit ÞDPAit (1)

LLPit ¼ b0 þ b1 LLAit þ b2 CHGOFFit þ b3 GLOANit þ b4 DLOANSit

CTAit ¼ a0 þ b1 TPit þ b2 SIZEit þ b3 LEVit þ b4 ROAit þ b5 GPit þ b6 TANGit

CTAit ¼ a0 þ b1 EMit þ b2 SIZEit þ b3 LEVit þ b4 ROAit þ b5 GPit þ b6 TANGit

CTAit ¼ a0 þ b1 TPit þ b2 EMit þ b3 ðTPit EMit Þ þ b4 LEVit þ b5 ROAit

4.1 Estimation strategy

Variable Obs Mean SD Min Max

CTA 82 0.0595 0.3317 2.1386 0.7753

Variable Obs Mean SD Min Max

CTA 137 0.0873 0.1123 0.0005 0.6527

5.2 Pearson correlation analysis

Financial multinational firms

5.3 Impact of transfer pricing on tax avoidance

5.4 The eﬀect of earnings management on tax avoidance

CTA 82 0.66271 23.626 6.939 0.00000

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