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Record W2008068612 · doi:10.7202/800680ar

La théorie des prix de transfert internes des grandes sociétés

2009· article· en· W2008068612 on OpenAlexvenueno aff
Lawrence Copithorne

Bibliographic record

VenueL Actualité économique · 2009
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicCorporate Taxation and Avoidance
Canadian institutionsnot available
Fundersnot available
KeywordsCorporationMultinational corporationDecentralizationTransfer pricingEconomicsArrowNeoclassical economicsSimple (philosophy)Market economyComputer scienceEpistemologyFinance

Abstract

fetched live from OpenAlex

There is considerable merit in thinking of the modern multidivisional corporation as an economy within itself. There is an important similarity between the interaction of divisions within a corporation and the perfectly competitive economic model formulated by Leon Walras1. When we look at modern corporations from this viewpoint we discover that much of what we know in general equilibrium economics may have considerable application inside modern corporations. Some of our existing theorems help clarify distinctions between decentralization and central control in corporate management in the same way that they clarify the distinctions between the market economies and those that run by central decree. They help distinguish which divisions must be centrally managed and those which can be left to look after themselves. This viewpoint offers new insights too—that, for instance, the products transferred between divisions may quite logically have two transfer prices instead of one. This viewpoint also permits an easy synthesis of the existing literature on transfer pricing. While the transfer pricing issue is especially important for multinational and international corporations which transfer goods and services between divisions located in different countries, the principles generally apply to any multidivisional corporation. The purposes of this paper are to present a simple, but general analytic model of the multidivisional corporation, to use it to make a synthesis of the existing literature on transfer pricing, and to make some important new discoveries. 1 Léon Walras, Elements of Pure Economics, édité et traduit par W. Jaffe (London : George Allen and Unwin, 1954). Kenneth Arrow fait mention de cette similitude dans son article : « Optimization, Decentralization and Internal Pricing in Business Firms », Contributions to Scientific Research in Management, 9-18, Western Data Processing Centre, Los Angeles, University of California Press, 1961.

Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.

How this classification was reachedexpand

Full frame machine prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.

metaresearch head score (Codex)0.003
metaresearch head score (Gemma)0.007
Version: metacan-v3-hybrid-931329e0061cValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Theoretical or conceptual · Consensus signal: Theoretical or conceptual
GenreCandidate signal: Empirical · Consensus signal: none
Teacher disagreement score0.015
Threshold uncertainty score0.049

Distilled classifier scores by category (both heads)

CategoryCodexGemma
Metaresearch0.0030.007
Meta-epidemiology (narrow)0.0010.001
Meta-epidemiology (broad)0.0010.001
Bibliometrics0.0030.002
Science and technology studies0.0030.008
Scholarly communication0.0050.011
Open science0.0020.003
Research integrity0.0030.006
Insufficient payload (model declined to judge)0.0150.002

Machine scores (provisional)

The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.

Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.

Opus teacher head0.053
GPT teacher head0.278
Teacher spread0.226 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it

Classification

machine, unvalidated

Machine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.

The models applied no category: nothing in the taxonomy fit this work.
Study designTheoretical or conceptual
Domainnot available
GenreEmpirical

How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".

Quick stats

Citations2
Published2009
Admission routes1
Has abstractyes

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