Multinational Corporations, Transfer Prices, and Taxes: Evidence from the U.S. Petroleum Industry

Economic research on transfer-pricing behavior by multinational corporadons has emphasized theoretical modeling and institutional description. This paper presents the fiit systematic empirical analysis of transfer prices, using data from the petroleum industry. On the basis of oil imported into the United States over the period 1973 - 1984, we test two propositions: i) Are prices set by integrated companies for their internal transfers different from those prevailing in arm 's-length (i.e., inter-company) trade, when other variables, such as oil quality, are controlled for? ii) Do average effective corporate income tar rates explain observed patterns of transfer pricing? Regression analysis leads to the following conclusions: i) Transfer and arm's-length prices differ significantly for oil origznating in some countries but not all. When multiplied by the relevant import volumes, these differences are relatively smalL The revenue transferred through deviations from arm's-length prices represents two percent or less of the value of the crude oil imported by multinational companies each year. ii) The observed differences between arm's-length and transfer prices are not easily explained by average effective tax rates in exporting countries. Our results provide little support for the claim that multinational petroleum companies set their transfer prices to evade taxes. We offer several hypotheses to explain our findings.

Electromagnetic Polarisability of the Nucleon in Chiral Perturbation Theory

We compute the polarisability of the nucleon to leading order in chiral perturbation theory. The contributions from kaons and baryon resonances as intermediate states are included in addition to the contribution from pions and nucleons that had been previously computed. The isoscalar operators are dominated by the infrared behaviour of pion loops giving rise to a $1/m_{\pi}$ coefficient. In contrast, the isovector operators are dominated by loops involving kaons, giving a $1/m_{k}$ coefficient, and further demonstrates that the strange quark is an important component of the nucleon. In addition, the inclusion of the decuplet of baryon resonances as intermediate states substantially modifies the result found from the octet baryons alone for the isoscalar polarisability.Comment: 11 pages (uses harvmac, figures available upon request) , UCSD/PTH 92-30, QUSTH-92-0

Virtual Compton Scattering and Generalized Polarizabilities of the Proton

Threshold photon electroproduction off the proton allows one to measure new electromagnetic observables which generalise the usual polarisabilities. There are -- a priori -- ten "generalised polarisabilities", functions of the virtual photon mass. The purpose of this paper is to lay down the appropriate formalism to extract these quantities from the photon electroproduction cross sections. We also give a first estimate of the generalised polarisabilities in the non relativistic quark model.Comment: 45 page postscript file including 2 figures (length just over 1Mb); also available at http://www.physics.adelaide.edu.au/theory/papers/ADP-94-25.T165.p

Electromagnetic Polarizabilities and Charge Radii of the Nucleons in the Diquark-model

The diquark model is used to calculate the electromagnetic polarizabilities and charge radii of the nucleons for three different potentials. Making the scalar diquark lower in mass introduces a mixing angle $\theta$ between the $\left| 56\right\rangle$ and $\left| 70\right\rangle$ states ,which allows an improvement in value of all 6 properties. Generalizing the Gamov-Teller matrix and the magnetic moment operator to the diquark model gives constraints on this mixing. We obtain for the Richardson potential $\theta =23.2^{\circ },$ $\overline{\alpha }_p=7.9_{-0.9}^{+1.0}\times 10^{-4}fm^3,$ $\overline{\alpha }_n=7.7_{-0.6}^{+0.3}\times 10^{-4}fm^3,$ $\overline{\beta }_p=5.4_{-0.4}^{+1.6}\times 10^{-4}fm^3,$ $\overline{\beta }_n=6.7_{-0.7}^{+1.3}\times 10^{-4}fm^3,$ $\left\langle r^2\right\rangle _p=0.37_{-0.03}^{+0.02}fm^2,$ $\left\langle r^2\right\rangle _n=-0.07_{-0.02}^{+0.03}fm^2.$ Additional pion cloud contributions could improve on all six results.Comment: 15 Pages, Latex, Figs on request, to be published Phys.Lett.B. Minor errors corrected and eqn 5,6,8,9 correcte

Electric Polarizability of the Nucleon in the Nambu--Jona-Lasinio Model

The electric polarizability of the nucleon is calculated in the soliton approach to the Nambu--Jona-Lasinio model. We analyze the leading-$N_c$ contributions, as well as the effects of rotational $1/N_c$ corrections and $\Delta$-$N$ mass splitting. Our model prediction is substantially reduced compared to other soliton calculations, and is closer to the experimental value.Comment: 16 pages, RevTeX, 3 figures (included, PS, uuencoded), RUB-TPII-55/93 and TPR-93-3

Dispersion relations in real and virtual Compton scattering

A unified presentation is given on the use of dispersion relations in the real and virtual Compton scattering processes off the nucleon. The way in which dispersion relations for Compton scattering amplitudes establish connections between low energy nucleon structure quantities, such as polarizabilities or anomalous magnetic moments, and the nucleon excitation spectrum is reviewed. We discuss various sum rules for forward real and virtual Compton scattering, such as the Gerasimov-Drell-Hearn sum rule and its generalizations, the Burkhardt-Cottingham sum rule, as well as sum rules for forward nucleon polarizabilities, and review their experimental status. Subsequently, we address the general case of real Compton scattering (RCS). Various types of dispersion relations for RCS are presented as tools for extracting nucleon polarizabilities from the RCS data. The information on nucleon polarizabilities gained in this way is reviewed and the nucleon structure information encoded in these quantities is discussed. The dispersion relation formalism is then extended to virtual Compton scattering (VCS). The information on generalized nucleon polarizabilities extracted from recent VCS experiments is described, along with its interpretation in nucleon structure models. As a summary, the physics content of the existing data is discussed and some perspectives for future theoretical and experimental activities in this field are presented.Comment: 120 pages, 42 figures, to appear in Phys. Re

Baryons as non-topological chiral solitons

The present review gives a survey of recent developments and applications of the Nambu--Jona-Lasinio model with $N_f=2$ and $N_f=3$ quark flavors for the structure of baryons. The model is an effective chiral quark theory which incorporates the SU(N$_f$)$_L\otimes$SU(N$_f$)$_R\otimes$U(1)$_V$ approximate symmetry of Quantum chromodynamics. The approach describes the spontaneous chiral symmetry breaking and dynamical quark mass generation. Mesons appear as quark-antiquark excitations and baryons arise as non-topological solitons with three valence quarks and a polarized Dirac sea. For the evaluation of the baryon properties the present review concentrates on the non-linear Nambu--Jona-Lasinio model with quark and Goldstone degrees of freedom which is identical to the Chiral quark soliton model obtained from the instanton liquid model of the QCD vacuum. In this non-linear model, a wide variety of observables of baryons of the octet and decuplet is considered. These include, in particular, electromagnetic, axial, pseudoscalar and pion nucleon form factors and the related static properties like magnetic moments, radii and coupling constants of the nucleon as well as the mass splittings and electromagnetic form factors of hyperons. Predictions are given for the strange form factors, the scalar form factor and the tensor charge of the nucleon.Comment: 104 pages, 27 figures as uuencoded and compressed postscript files , hardcopy available upon request; Prog.Part.Nucl.Phys. 37 (1996) (in print