And its worth noting why we should not necessarily assume the US figure is representative for lower income countries....https://twitter.com/MForstater/status/1116252157546827776 …
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And this makes sense when you think about what we are talking about e.g. trade between an Apple subsidiary in one country and an Apple subsidiary (or branch) legally incorporated in another. Its not just about Apple products (or components) crossing borders.
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Similarly e.g. when Cadbury buy cocoa beans from farmers in Ghana my guess is there is no related party transaction going on, because just buying in a country does not create a permanent establishment.
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So alot of what we might intuitively think of as being trade involving multinational corps is not intrafirm (i.e. not subject to transfer pricing).... this was the origin of the original misunderstanding of the UNCTAD 60% figure which includes both types.
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Cocoa is probably bought by a procurement hub and on-sold to manufacturing subsidiaries
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Right, so there is transfer pricing between the procurement hub (e.g. in Switzerland) and the manufacturing subsidiary, but not between the farm gate and the procurement hub.
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