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1
Galilea, Gisele Walczak. "'Tax deferral' and shareholding structure of multinational firms." reponame:Repositório Institucional do FGV, 2018. http://hdl.handle.net/10438/25679.
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While firms are looking for tax savings through the choice of investment projects (i.e., through investments in new foreign subsidiaries in countries with the lowest tax rate), countries are aware that firms are sensitive to tax factors and thus adopt instruments such as tax deferral to prevent the 'flight' of capital. However, by discouraging repatriation, this tax instrument promotes 'multinationals' flight' (i.e., the corporate inversion of multinationals). This paper demonstrates that instruments such as tax deferral accelerate the process of 'multinational flight of the home country'. Using both a reduced form analysis and a dynamic structural model, we find that multinationals in countries with a worldwide system of taxation and tax deferral have a greater incentive to avoid residual taxation of foreign earnings in the home country and therefore repatriate less than half of their foreign earnings. In turn, this 'nonrepatriation' increased the probability of relocation by 4.4%.
Enquanto as empresas buscam economizar impostos através da escolha de determinados projetos de investimento (ou seja, investindo em novas subsidiárias estrangeiras em países com a menor alíquota de impostos), os países, por sua vez, estão cientes de que as empresas são sensíveis as questões tributárias e adotam instrumentos como diferimento de impostos para impedir o 'voo' do capital. Contudo, ao desencorajar a repatriação, esse instrumento fiscal promove o 'voo das multinacionais' (ou seja, a inversão corporativa das multinacionais). Este trabalho demonstra que instrumentos como o diferimento de impostos aceleram o processo de 'voo da multinacional do país de origem'. Utilizando uma análise na forma reduzida e um modelo estrutural dinâmico, descobrimos que as multinacionais localizadas em países com um sistema mundial de tributação e diferimento de impostos têm um incentivo maior para evitar a tributação residual dos rendimentos estrangeiros no país de origem e, portanto, repatriam menos da metade de seus ganhos estrangeiros. Essa 'não-repatriação', por sua vez, aumenta a probabilidade de realocação em 4,4%.
2
Hoppe, Thomas [Verfasser]. "The impact of tax complexity on multinational corporations / Thomas Hoppe." Paderborn : Universitätsbibliothek, 2020. http://d-nb.info/1210026228/34.
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Wendt, Carsten. "A Common Tax Base for Multinational Enterprises in the European Union." Wiesbaden : Gabler Edition Wissenschaft, 2009. http://dx.doi.org/10.1007/978-3-8349-8193-6.
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Mulligan, Emer. "Tax planning in practice : a field study of US multinational corporations." Thesis, University of Warwick, 2008. http://wrap.warwick.ac.uk/1113/.
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The aim of this study is to achieve a better understanding of tax planning in practice, identifying and taking account of the multiple arenas within which it operates, and thereby highlighting its social and institutional dimensions. In the current rapidly changing business and regulatory environment, in which tax is an extremely important source of revenue for governments around the world, an enhanced understanding of tax planning in practice benefits and has implications for taxpayers and tax policymakers alike. The four research questions posed in this study address: the organisation and strategic alignment of the tax planning function in multinational corporations (MNCs); performance measurement of this function; tax risk management; the nature and impact of the relationship between the tax planning function within MNCs and the external environment within which it operates. Empirically this study focuses on US MNCs, primarily in respect of mainstream corporation tax planning. In line with the interpretive inductive methodological approach adopted, face-to-face interviews were conducted with senior tax executives in US MNCs, and tax advisors to such companies. A theoretical framework is developed which combines core themes and theoretical constructs within three strands of literature, namely, tax planning, new institutional sociology and endogeneity of law. This framework provides a powerful explanatory lens through which the findings are presented and interpreted. The role ofpower and powerful actors is an important and recurring theme, and partly explains prevailing tax planning practices through the intensity of professional and social interaction between tax executives. Increasingly tax risk management is more important and there is evidence that this may change the way in which the tax planning function is given strategic recognition and integrated operationally. with business units. The focus on tax risk management results in an isomorphic trend towards conservatism in tax planning, and competitor and peer company influence are significant in shaping tax risk management mechanisms. Measuring the performance of the tax planning function is found to be variable, although there was a view that the effective tax rate (ETR), although an important external measure of corporate performance, was inappropriate as an internal measure. Tax laws are often portrayed as exogenous factors, however this study has found that companies invest heavily in external affairs and direct lobbying to secure changes in the law to suit their purposes; evidencing its endogeneity. Networking costs, reputational risk management and lobbying costs therefore represent non-tax costs that are difficult to measure, but are important components of tax planning activities, overlooked in the current tax planning literature. In addition to the findings themselves this study contributes to knowledge through its interpretive methodological approach which provides a new and rich perspective on tax planning in practice, highlighting some shortcomings of the positivistic approach. It also develops a theoretical framework which uniquely combines theoretical constructs from three strands of literature.
5
Karlsson, Victor. "There is no place like home, or is there? : A difference-in-differences analysis of the effect of the 2013 Swedish corporate tax policy change on Swedish multinational companies’ tax avoidance." Thesis, Uppsala universitet, Nationalekonomiska institutionen, 2021. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-451265.
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Recent empirical literature has provided greater insight into the strategies and the extent of multinational companies’ tax avoidance. Simultaneously, in the last decades, the corporate tax rate has gradually decreased in most developed countries, often in the interest of attracting foreign investment. In 2013, Sweden decreased its corporate tax from 26.3% to 22%. This paper is an empirical study of the effect of the corporate tax change on Swedish multinational companies’ tax avoidance. By using a difference-in-differences model, and a sample of firm-level financial data from 19 821 domestic and multinational Swedish companies covering the period 2011 – 2015, a regression analysis is performed to estimate the effect of the policy change. Irrespective of empirical specification, I find no statistically significant effect of the tax change on tax avoidance.
6
Ortmann, Regina, and Caren Sureth. "Can the CCCTB Alleviate Tax Discrimination Against Loss-making European Multinational Groups?" WU Vienna University of Economics and Business, Universität Wien, 2014. http://epub.wu.ac.at/4168/1/SSRN%2Did2442820.pdf.
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In March 2011, the European Commission submitted a proposal for a Council Directive on an optional common consolidated corporate tax base (CCCTB). If this proposed CCCTB system comes into force, taxes calculated under the currently existing system of separate accounting might be replaced by a system of group consolidation and formulary apportionment. Then, multinational groups (MNGs) would face the decision as to whether to opt for the CCCTB system. Prior research focuses mainly on the differences in economic behaviour under both systems in general. By con-trast, we study the conditions under which one or the other tax system is preferable from the per-spective of an MNG, with a particular focus on loss-offsets. We identify four effects that determine the decision of an MNG: the tax-utilization of losses, the allocation of the tax base, the dividend and intragroup interest taxation. We find mixed results, e.g., that the CCCTB system proves ad-vantageous for increasing loss/profit streams (e.g. from start-ups or R&D projects) of the individual group entities, whereas the system of separate accounting is beneficial for decreasing profit/loss streams (e.g. caused by a decrease in return from a mature product). The results of our analysis are helpful for MNGs facing the decision as to whether to opt for the CCCTB system and can also support legislators and politicians in the EU but also in other regions in their tax reform discussions. (authors' abstract)Series: WU International Taxation Research Paper Series
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Ortmann, Regina, and Caren Sureth-Sloane. "Can the CCCTB alleviate tax discrimination against loss-making European multinational groups?" Springer Berlin Heidelberg, 2016. http://dx.doi.org/10.1007/s11573-015-0780-6.
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In March 2011, the European Commission submitted a proposal for a Council Directive on an optional common consolidated corporate tax base (CCCTB). If this proposed CCCTB system comes into force, taxes calculated under the currently existing system of separate accounting might be replaced by a system of group consolidation and formulary apportionment. Then, multinational groups (MNGs) would face the decision as to whether to opt for the CCCTB system. Prior research focuses mainly on the differences in economic behaviour under both systems in general. By contrast, we study the conditions under which one or the other tax system is preferable from the perspective of an MNG, with a particular focus on loss-offsets. We identify four effects that determine the decision of an MNG: the
tax-utilization of losses, the allocation of the tax base, the dividend and intragroup interest taxation. We find mixed results, e.g., that the CCCTB system proves advantageous for increasing loss/profit streams (e.g. from start-ups or R&D projects) of the individual group entities, whereas the system of separate accounting is beneficial for decreasing profit/loss streams (e.g. caused by a decrease in return from a mature product). The results of our analysis are helpful for MNGs facing the decision as to whether to opt for the CCCTB system and can also support legislators and politicians in the EU but also in other regions in their tax reform discussions. (authors' abstract)
8
Richter, Katharina Verfasser], and Christoph [Akademischer Betreuer] [Spengel. "Research and Development Tax Planning of Multinational Firms / Katharina Richter. Betreuer: Christoph Spengel." Mannheim : Universitätsbibliothek Mannheim, 2015. http://d-nb.info/1074102584/34.
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Hebous, Shafik, and Alfons Weichenrieder. "What Do We Know about the Tax Planning of German-Based Multinational Firms?" WU Vienna University of Economics and Business, Universität Wien, 2014. http://epub.wu.ac.at/4355/1/SSRN%2Did2521387.pdf.
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Abundant anecdotal evidence is in accord with rigorous research results confirming the existence of
various forms of international tax planning by multinational firms. Increasing availability of
administrative data for research purposes has enabled researchers to study not only behavioural
responses of US-based firms to taxation, but also of European and other multinationals. The present
paper summarizes what we can learn from recent studies on tax avoidance strategies by
multinational firms in general and by German multinationals in particular. (authors' abstract)Series: WU International Taxation Research Paper Series
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Richter, Katharina [Verfasser], and Christoph [Akademischer Betreuer] Spengel. "Research and Development Tax Planning of Multinational Firms / Katharina Richter. Betreuer: Christoph Spengel." Mannheim : Universitätsbibliothek Mannheim, 2015. http://nbn-resolving.de/urn:nbn:de:bsz:180-madoc-389865.
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Hoppe, Thomas, Deborah Schanz, Susann Sturm, and Caren Sureth-Sloane. "What are the Drivers of Tax Complexity for Multinational Corporations? Evidence from 108 Countries." WU Vienna University of Economics and Business, Universität Wien, 2017. http://epub.wu.ac.at/5797/1/delivery.pdf.
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All over the world, firms and governments are increasingly concerned about the
rise in tax complexity. To manage it and develop effective simplification measures, detailed
information on the current drivers of complexity is required. However, research on this topic
is scarce. This is surprising as the latest developments - for example, triggered by the BEPS
project - give rise to the conjecture that complexity drivers may have changed, thus questioning
the findings of prior studies. In this paper, we shed light on this issue and provide a
global picture of the current drivers of tax complexity that multinational corporations face
based on a survey of 221 highly experienced tax practitioners from 108 countries. Our results
show that prior complexity drivers of the tax code are still relevant, with details and changes
of tax regulations being the two most influential complexity drivers. We also find evidence
for new relevant complexity drivers emerging from different areas of the tax framework, such
as inconsistent decisions among tax officers (tax audits) or retroactively applied tax law
amendments (tax enactment). Based on the responses of the practitioners, we develop a concept
of tax complexity that distinguishes two pillars, tax code and tax framework complexity,
and illustrates the various aspects that should be considered when assessing the complexity
of a country's tax system.Series: WU International Taxation Research Paper Series
12
Huang, Jingjing. "The Role of Taxes in Foreign Earnings Management: Implications for Pricing of Foreign Earnings." Thesis, University of Oregon, 2014. http://hdl.handle.net/1794/18326.
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U.S. multinational corporations are well known for shifting income to low tax foreign subsidiaries to avoid U.S. income tax. Yet little is known about how multinational corporations opportunistically use low tax foreign subsidiaries for financial reporting purpose. Understanding this question has implications for U.S. accounting regulators to set enforcement targets. Using worldwide consolidated financial statements, I examine the role of taxes for multinational corporations to manage earnings in foreign subsidiaries. I find that by managing earnings in low tax foreign countries, multinational corporations can reduce the effective tax rate on pretax accrual earnings by an average of 4.3%. To examine the implication of opportunistic foreign earnings management on investors' equity valuation, I find evidence that investors do not seem to overvalue foreign managed earnings compared to domestic managed earnings, though foreign earnings are on average valued higher than domestic earnings.
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Cooper, Maggie. "What drives the tax avoidance strategies adopted by US MNEs? : understanding the heterogeneity of approaches to corporate tax planning in US multinational enterprises." Thesis, University of Reading, 2018. http://centaur.reading.ac.uk/77929/.
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‘Beside the great issues of progress, sovereignty and economic justice that swirl around the MNE, taxation sounds like a matter for petty minds that warm to accountancy. That instinct is squarely wrong, because it turns out that arrangements for taxing corporate net incomes constitute the dominant factor in the division of spoils between source and host country’ Caves (1982). In recent years tax avoidance has come under scrutiny from the public, the media and the government. Tax planning is the way in which companies efficiently manage the payment of taxes using a variety of methods to reduce tax legally. It is a key function of multinational enterprises (MNEs), yet little is known about the way in which it is implemented. Internalization theory underpins the research contained in this thesis which argues that early International Business (IB) theory had a more explicit focus on tax and the opportunities that it confers on the MNE. Tax, it is argued, gives MNEs a financial advantage over domestic companies. The development of IB theory more recently has failed to build on this early understanding and consequently tax has become a neglected topic within the field of IB. This study aims to enhance our understanding of tax planning phenomena and the way in which US MNEs are able to manage their Effective Tax Rate (ETR). It is an innovative study, considering the importance of tax planning to the MNE as well as providing new insight into the way in which tax planning is conducted within the MNE. Mixed methods of qualitative and quantitative research are used in this study which helps to examine the MNE’s tax planning in a holistic and systematic manner. This includes in-depth and detailed analysis from the parent-firm level to the subsidiarylevel, and interviews with subsidiary managers and tax experts to obtain their insights and views. Specifically, a series of interviews with senior tax executives from UK subsidiaries of US MNEs and experts from tax advisory firms is conducted, focusing on the experience of the MNE subsidiary operating in the UK. The study shows the 6 importance of the people within the business in terms of setting the tone for tax planning and strategy and the risk that the organisation is prepared to take. A quantitative study examines 94 large US MNEs from the group perspective. The analysis uses two different measures of the ETR and a measure of the cash held by the company to improve the understanding of the ways in which tax-planning strategies are implemented. The analysis unpicks the impact of different characteristics of the companies to add to our understanding of what drives the heterogeneity of approaches in place. A series of six case studies is used in the final section to reconcile the findings from the two empirical studies – the interviews and the parent-level data analysis. Using published accounting data and other company information (e.g. management discussion, disclosure notes, and organizational structure and business configuration) the case studies make a clear contribution by providing detailed analysis of the companies involved over a ten year time horizon. Key Findings and Contributions This study makes a new key theoretical contribution by extending knowledge about the motivations and abilities of MNEs to plan their tax affairs efficiently. Early work within IB considered transfer pricing alone and this subject has then been neglected in recent years. This study demonstrates that transfer pricing is only one part of the complex tax (and tax planning) interactions between governments and MNEs. It highlights the need to distinguish between the value appropriation (rent seeking) aspirations of MNEs, which are the primary concern of governments, and the value creation (efficiency based) internalization activities of MNEs as they use internal prices to overcome exogenous market imperfections (Rugman, 1980). Furthermore, findings from the interview research suggest the importance of aspects, such as the experience of the individuals’ and the company’s overall attitude to risk that the development of theory must take into account. This thesis reaffirms the centrality of financial planning (an in particular tax planning) to internalization theory. 7 Early theoreticians could not test the economic models that they developed. The quantitative research in this thesis builds an economic model which is then tested empirically. The importance of the size of a firm, the use of intellectual property, the use of small tax havens and the proportion of women on the board are found to be important factors in determining the aggressiveness of the tax stance adopted by US MNEs. The findings from this research have important implications for policy makers by providing new and useful insights into the way in which MNEs plan their tax strategies. The research will also be of interest to managers within the firm, adding to their understanding of the role of tax in corporate strategy.
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Ortmann, Regina. "Uncertainty in Weighting Formulary Apportionment Factors and its Impact on After-Tax Income of Multinational Groups." WU Vienna University of Economics and Business, Universität Wien, 2015. http://epub.wu.ac.at/4609/1/SSRN%2Did2521386.pdf.
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Formulary apportionment is an intensively debated mechanism for allocating tax base within
multinational groups. Systems under which the formula is identical in all jurisdictions and systems
under which jurisdictions can determine the weights on the formula factors individually can be
observed. The latter systems produce uncertainty about the overall tax-liable share of the future group
tax base. Counter-intuitively, I identify scenarios under which increased uncertainty leads to higher
expected future group income. My results provide helpful insights for firms and policy makers
debating the specific design of a formulary apportionment system. (author's abstract)Series: WU International Taxation Research Paper Series
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Nessa, Michelle Lynn. "The U.S. tax and financial reporting treatment of foreign earnings and U.S. multinational companies' payout policies." Diss., University of Iowa, 2014. https://ir.uiowa.edu/etd/4706.
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This paper examines the impact of the U.S. tax and financial reporting treatment of foreign earnings on the payouts to shareholders of U.S. multinational companies (MNCs). I find the U.S. tax and financial reporting treatment of foreign earnings weakens the otherwise strong, positive association between foreign earnings and the probability and level of dividend payments, but I do not observe an effect on the probability or level of stock repurchases or on the level of total payout. I also find U.S. MNCs with tax and/or financial reporting incentives to keep their foreign profits reinvested abroad make more extensive use of repurchases than dividends when making distributions to shareholders. This study contributes to our understanding of the impact of the current U.S. worldwide tax system on U.S. MNCs' real decisions.
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Harendt, Christoph [Verfasser], and Ulrich [Akademischer Betreuer] Schreiber. "Tax avoidance of multinational entities : an empirical analysis of tax effects on investment, financial structures and repatriation of profits / Christoph Harendt ; Betreuer: Ulrich Schreiber." Mannheim : Universitätsbibliothek Mannheim, 2019. http://d-nb.info/1175878979/34.
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Shi, Ruoxi. "The effects of the BEPS Action Plans on the tax avoidance behaviors of multinational corporations in China." HKBU Institutional Repository, 2018. https://repository.hkbu.edu.hk/etd_oa/598.
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Multinational corporations (MNCs) around the globe commonly use cross-border related-party transactions (CRPTs) to shift profits from high tax jurisdictions to low ones to avoid paying taxes. The Organization for Economic Co-operation and Development and G20 countries launched the Base Erosion and Profit Shifting (BEPS) Action Plans in 2013 to constrain tax avoidance behaviors of MNCs, particularly the widespread use of CRPTs. This study examines how the localization of the BEPS Action Plans affects the tax avoidance behavior of MNCs in China. Using all the listed non-financial MNCs on the Stock Exchanges in China from 2012 to 2017, I find that: (1) Chinese MNCs with more CRPTs are more likely to pay less taxes than those with less CRPTs. Localization of the BEPS Action Plans does not have significant impact on this behavior. (2) The effect of localization of BEPS Action Plans to constrain corporate tax avoidance is more pronounced on MNCs with relatively poor information quality in the pre-location period; (3) local government-controlled firms (LG firms) with more CRPTs engage in more tax avoidance, but localization of the BEPS Action Plans significantly constrains tax avoidance activities by these firms in the post-location period. These findings should shed light on what mechanisms could constrain MNCs’ tax avoidance, especially income shifting through CRPTs, and how it could be affected by tightening of the tax laws on tax avoidance activities and by ownership structure in a developing country setting, in particular.
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El-Sharkawy, Mosaad M. "The location decision of the multinational corporation and the national tax accounting system : the case of Egypt." Thesis, University of St Andrews, 1989. http://hdl.handle.net/10023/2915.
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Foreign direct investment has attracted many researchers and scholars. In Egypt, this topic has been discussed and debated by economists, the People's Assembly and Cabinet Ministers since the President of the Republic declared the adoption of the policy of economic openness "Al-Infitah" in June 1974. This new economic approach aimed to encourage the inflow of foreign capital into Egypt in an attempt to solve the mounting problems of the Egyptian economy, mainly growth of the population, shortage of foreign exchange, and persistent deficit of the balance of payments. The main purpose of this study has been to investigate the impact of the Egyptian Tax Accounting System on the foreign decision to invest in Egypt. The main concentration is on the general tax principles applied to foreign corporations in Egypt, the impact of tax incentives, in general, on the inflow of foreign capital into Egypt, the key tax and non-tax problems encountered by foreign investors in Egypt, and the main tax and non-tax motives for investment in Egypt. The findings of this study and the insights gained about the nature of foreign investment in Egypt, provide the basis for some recommendations and suggestions for the effective implementation of the "Open Door" policy declared by the government for the purpose of attracting foreign investment.
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Peerbhai, Aneesa. "Base erosion and profit shifting by multinational corporations and weaknesses revealed in South African income tax legislation." Thesis, Rhodes University, 2015. http://hdl.handle.net/10962/d1017540.
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This research examined the concept of base erosion and profit shifting in the context of tax schemes employed by multinational corporations. The objective of this thesis was to identify weaknesses within South Africa’s income tax legislation, based on these schemes, and further to propose recommendations to counter the occurrence of base erosion and profit shifting by multinational companies. The research also comprised of a limited review of current global and South African initiatives to address the problem of base erosion and profit shifting. It was concluded that there are a number of weaknesses in the definitions and provisions of the South African income tax legislation that need to be addressed in order to reduce base erosion and profit shifting. Brief recommendations were proposed in relation to each of the weaknesses, in order to address them.
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Foster, Sheila Dale. "An empirical investigation of the ability of multinational enterprises to affect their United States income tax liability." Diss., Virginia Tech, 1994. http://hdl.handle.net/10919/37900.
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Transfer prices are the prices charged by one party for goods and/or services transferred to a related party. While transfer prices are essential to the goal of profit maximization within the enterprise, difficulties arise over how to establish the "correct" transfer price. For the global enterprise this problem is more acute because different segments of the enterprise operate under different political jurisdictions and are subject to taxation by different political entities. Concerns have been raised by Congress and the Internal Revenue Service regarding whether multinationals, especially foreign-owned multinationals, are using transfer-pricing and cost-allocation policies across international borders to avoid United States income taxes. Generally, testimony before the hearings, limited anecdotal studies, and court case findings have suggested that multinationals do not pay their "fair share".
An examination of 336 companies in the chemical industry (STC codes 2800-2899) provided mixed support for the position that multinationals are paying less than their "fair share" of U.S. income taxes. While statistically significant differences were found among the three groups for the cost-ofgood-sold (COGS) ratio (after developmental stage enterprises were removed) and for the worldwide net-profit ratio, no Statistically significant differences were found for tax-rate measures (worldwide effective income tax rate, worldwide effective operating income tax rate, and U.S. effective operating income tax rate) or for the return measures (worldwide return on assets, worldwide operating return on assets, and U.S. operating return on assets). When multinationals (U.S.-controlled and foreign-controlled combined to form a single group) were compared to domestic companies, statistically significant differences were found only for the COGS ratio. When U.S. multinationals were restricted to those companies with 50% or more of both their net sales and average total assets abroad, statistically Significant differences were found for the operating income ratios (both U.S. and worldwide) and for the worldwide net profit ratio, but such differences were found neither for the COGS ratio, the effective-income-tax-rate measures, nor for the return measures.
Complicating the issue were: (1) the presence of developing stage enterprises and foreign parent companies among the total group; (2) the use of a 10% cutoff in ownership and operations to determine whether a company is or is not a multinational; and (3) the absence of access to tax or accounting records, resulting in the need to use secondary sources for data.
One suggestion for simplifying the transfer-pricing issue is the adoption of a method of formulary apportionment. Ina comparison of the amount of income allocated to U.S. operations under current methods (either specific allocation Or separate accounting) and the amount that would have been allocated under formulary apportionment methods no significant differences were found, suggesting that such a method is worthy of further study.Ph. D.
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Onyejekwe, Chisa. "Using corporate tax regimes to promote economic growth and development : a legal analysis of the Nigerian corporate tax regime." Thesis, Robert Gordon University, 2017. http://hdl.handle.net/10059/2509.
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The recession that started in the late 2000s has created significant economic and financial challenges globally and within nation states. In particular, oil-producing countries have been further affected by the fall in oil price. It is therefore crucial that alternative, more sustainable methods of sourcing revenue be investigated and utilised. The purpose of this thesis therefore is to examine the use of corporate tax regimes as a sustainable revenue source in promoting economic growth and development in Nigeria. Using a qualitative legal analysis, of the Nigerian corporate tax regime and through an extensive literature review, the thesis identified a number of key findings. Inter alia, that revenue from corporation tax structures are a sustainable revenue source mostly because of the amount of revenue generated through Multinational Corporations (MNCs). Secondly, the existing Nigerian corporation tax regime is in need of reform as there are developmental challenges, including lack of implementation and ambiguous legislation, which continue to thwart its success. Therefore, this leads to establishing how, and to what extent that Nigeria can use its corporate tax regime as a sustainable revenue source. The answer to this lies in the legal framework of corporate tax regimes. This thesis argues that legal uncertainties in the corporate tax regimes are the principal reason for the challenges faced by both state governments and MNCs. The thesis concludes by recommending reforms to the Nigerian tax regime while also recommending a tax compliance strategy for both domestic and international corporate tax regimes. This will set a foundation for corporation tax regimes as a sustainable revenue generation source for developing countries.
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Loomer, Geoffrey T. "Reformulating corporate residence : a coherent response to international tax avoidance." Thesis, University of Oxford, 2011. http://ora.ox.ac.uk/objects/uuid:1f515456-3d87-4942-9600-b9cfe73c6662.
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This thesis analyzes the concept of corporate residence, with particular reference to the law in the UK and Canada. It explores why corporate residence is relevant in tax policy, how corporate residence is understood in law, and how revenue authorities respond to the use and alleged 'abuse' of residence rules. Part I argues that the residence of taxpayers generally (individual or corporate) remains a relevant factor in international tax design, that taxation of corporations on the basis of residence has some justification, but that there is a disjunction between meaningful residence-based taxation and current definitions of corporate residence in domestic law and tax treaties. The formulations of residence based on incorporation, central management and control, and place of effective management, particularly as applied to multinational enterprises, are considered and are found to be deficient. Part II critically analyzes the major policy responses of the UK and Canadian governments to the exploitation of corporate residence. It argues that key legislative and administrative responses to international tax avoidance activities, for both outbound and inbound investment, are purportedly based on the acceptance of formal corporate residence yet undermine that concept in an effort to impose tax or refuse treaty relief based on where economic interests actually exist. The responses considered are the application of controlled foreign companies legislation to offshore subsidiaries, the invocation of treaty anti-abuse rules with respect to offshore intermediaries, and the use of overarching general anti-avoidance measures to challenge varied structures that rely on offshore entities. These haphazard anti-avoidance rules are overlaid with revenue authorities' indignation at the motivations that underlie many corporate relocations. It is argued that a more coherent approach would be to focus on the objective reality or unreality of corporate establishment, by reformulating corporate residence in domestic law and tax treaties.
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Prettl, Axel [Verfasser]. "The international tax law of Controlled Foreign Corporation rules and their influence on multinational companies' behaviour / Axel Prettl." Tübingen : Universitätsbibliothek Tübingen, 2021. http://d-nb.info/1236994019/34.
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Bellak, Christian, and Markus Leibrecht. "Effective tax rates as a determinant of foreign direct investment in Central- and East European countries. A panel analysis." SFB International Tax Coordination, WU Vienna University of Economics and Business, 2005. http://epub.wu.ac.at/1572/1/document.pdf.
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The Central- and East European Countries have lowered their corporate tax rates substantially in order to induce shifts of production capacity to their countries. This paper analyses empirically how inward Foreign Direct Investment (FDI) flows channeled to these countries reacts to these tax policies. We estimate a panel of 35 bilateral country-relationships over a period of 1995-2002. Results suggest a semielasticity of -2.93 which is in line with results derived in studies mainly on OECD countries. This indicates that from an individual country perspective, tax-lowering strategies have been successful in the past, yet they may not be a successful policy option for the future when privatization-related FDI will decrease.Series: Discussion Papers SFB International Tax Coordination
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Adetonah, Ghislain Serge Odon. "L’évasion fiscale des multinationales dans les pays de l’UEMOA." Thesis, Aix-Marseille, 2018. http://www.theses.fr/2018AIXM0055/document.
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Les pays de l’UEMOA, longtemps hostiles aux investissements directs étrangers, sous l’effet conjugué de la globalisation de l’économie et de la pression des institutions de Brettons Woods, ont d’une part, favorisé un accès intérieur aux flux financiers internationaux et d’autre part, offert des incitants fiscaux aux multinationales. Grâce à la libéralisation financière et l’idéologie économique dominante, les multinationales, par différents subterfuges et profitant aussi des handicaps institutionnels et organisationnels des administrations fiscales respectives des pays membres de l’espace UEMOA, échappent à leurs responsabilités fiscales envers ces États. Pour résorber les effets néfastes de l’évasion fiscale des multinationales, les pays de l’espace communautaire UEMOA, doivent mettre un accent particulier sur la modernisation de leurs administrations fiscales d’une part, et d’autre part, insérer dans toutes leurs conventions fiscales, des clauses anti-abus. Enfin, ces États doivent renforcer la lutte contre l’évasion fiscale par une action concertée basée sur une coopération fiscale dans le cadre d’une assistance administrativeThe WAEMU countries, long hostile to foreign direct investment, under the combined effect of the globalization of the economy and the pressure of the institutions of Brettons Woods, have in the one hand, favored an internal access to International financial flows and on the other hand, offered tax incentives to multinationals. Thanks to financial liberalization and the prevailing economic ideology, the multinationals, by various subterfuges and taking advantage also of the institutional and organizational handicaps of the respective tax administrations of the member countries of the UEMOA space, escape their fiscal responsibilities towards these states. In order to reduce the harmful effects of tax evasion by multinationals, WAEMU countries must place particular emphasis on the modernization of their tax administrations on the one hand, and on the other hand, to include in all their agreements tax rules, anti-abuse clauses. Finally, these states must strengthen the fight against tax evasion by concerted action based on tax cooperation in the context of administrative assistance
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Bellak, Christian, Markus Leibrecht, and Roman Römisch. "New evidence on the tax burden of MNC activities in Central- and East-European new member states." SFB International Tax Coordination, WU Vienna University of Economics and Business, 2005. http://epub.wu.ac.at/1120/1/document.pdf.
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Company-taxation policies in the Central and East European New Member States (CEE-NMS) have been frequently characterised as tax-cutting strategies in order to attract Foreign Direct Investment (FDI). On the basis of a survey of six empirical studies a median value of the tax-rate elasticities of FDI of -0.22 in CEE-NMS and mediterranean periphery countries is derived. Yet, these tax-rate elasticities probably suffer from a sort of measurement error bias since these studies entirely rely on the host country Statutory tax rate as measure of tax burden. Building on a thorough criticism of FDI as a measure reflecting multinational activity and the Statutory tax rate as a reliable measure of the effective tax burden, 315 effective average bilateral tax rates (BEATR) are calculated for seven home countries and five CEE-NMS for the period 1996-2004, following the approach of Devereux and Griffith (1998). Since our empirical results show substantial differences in the variability of the host country Statutory tax rates and the BEATRs, it is contended that the latter should be used as explanatory variables in empirical studies.Series: Discussion Papers SFB International Tax Coordination
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Hagen, Dominik von [Verfasser], and Ulrich [Akademischer Betreuer] Schreiber. "Profit shifting of multinational entities - empirical analysis of effective tax rates, mergers & acquisitions and financing structures / Dominik von Hagen ; Betreuer: Ulrich Schreiber." Mannheim : Universitätsbibliothek Mannheim, 2018. http://d-nb.info/1154386198/34.
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Pavey, Janet Gail. "An exploration of whether using a global employment company could mitigate the South African tax risks in relation to inbound expatriates in multinational companies." Thesis, Rhodes University, 2018. http://hdl.handle.net/10962/61368.
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The main objective of this research paper was to explore whether a multinational company could use a global employment company to employ its expatriates to mitigate, simplify or limit the tax risk for that foreign company when sending expatriates to South Africa. To investigate this topic, an interpretive research approach was used, a doctrinal research methodology was followed, and inductive reasoning was applied. The documentary data used in this research was publicly available. Firstly, the meaning of the term “expatriate” was explored, together with the types of employment arrangements commonly used to employ this type of employee. The South African tax consequences that an inbound expatriate may create for a multinational company were then analysed. These tax consequences were applied to the common types of employment arrangements to determine what the South African tax impact of these arrangements is likely to be and which entity within a multinational group is likely to be affected. It was investigated whether using a foreign global employment company provides any tax simplification or tax mitigation strategies for the multinational company for expatriates inbound to South Africa. The primary conclusions of this research were that it was found that using a global employment company may only provide a tax benefit in South Africa in very specific circumstances: (i) where the economic employer of the expatriate is the South African entity; (ii) where flexibility is required to easily move the expatriate to other jurisdictions; and (iii) where there are multiple home-host country combinations that the multinational group needs to consider when moving its expatriates. It would appear that using a global employment company as the employment arrangement for an inbound expatriate to South Africa may have a fairly limited application if its purpose is to mitigate tax risks. In effect, a global employment company is likely to provide tax benefits only where it acts as an international labour broker for the multinational company of which it is a part.
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Wardhana, Andy Whisnu. "A policy proposal to address tax base erosion caused by transfer pricing in Indonesia." Thesis, Queensland University of Technology, 2019. https://eprints.qut.edu.au/125858/1/Andy%20Whisnu_Wardhana_Thesis.pdf.
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Prior studies indicate that developing countries face the problem of aggressive transfer pricing practices by multinational enterprises (MNEs) which cause tax base erosion. This study finds that the Indonesian transfer pricing regime fails to accurately allocate the income of MNEs among taxing states in accordance with actual economic reality. To overcome this problem, this study considers different interpretations of transfer pricing regimes in four countries: (a) Mexico's minimum profit, (b) Brazil's pre-fixed profit margin and (c) India's and China's location-specific advantage rules. This study argues that adopting the location-specific advantage criteria for determining an arm's length price could help Indonesia address the problem of aggressive transfer pricing practices and assist Indonesia to reduce tax base erosion.
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Foltysová, Nikol. "Analýza agresivního daňového plánování ve vztahu k fúzím obchodních společností a družstev." Master's thesis, Vysoká škola ekonomická v Praze, 2017. http://www.nusl.cz/ntk/nusl-360131.
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The diploma thesis deals mainly with aggressive tax planning of multinational companies but also mentions the practices of domestic enterprises, which lead up to the reduction of the tax liability of the entity. The main idea of the thesis is a description of indicators and the analysis of structures of companies performing aggressive tax planning. The practical part of this thesis contains model examples, which can be realized and against which it is necessary to intervene. The last chapter describes measures by which the OECD and the European Union institutions are trying to eliminate the abuse of tax laws and bilateral treaties by multinational corporations. The Czech Republic has already implemented a number of measures against aggressive tax planning, which success in this diploma thesis is tested by comparing year-by-year revenues changes from corporate income tax.
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Hansen, Ida, and Viktoria Lin. "China - The new Corporate Income Tax Law and its effect on Transfer Pricing : and in particular the issue of documentation requirements." Thesis, Jönköping University, JIBS, Commercial Law, 2008. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-1140.
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China has had a remarkable development since the late 1970s, when the Chinese government started opening up its internal market for the outside world. The Chinese legislation and the legal system itself have been developing rapidly to adapt to the new economic environment, however not without complications. Many uncertainties still remain.
Under the old income tax regime, corporations on the Chinese market were taxed under two different systems, one for domestic enterprises and one for foreign invested enterprises and foreign enterprises. With the new Corporate Income Tax Law, these two systems were merged and new concepts introduced. The new income tax law includes important articles that affect the transfer pricing regime in China. The OECD’s transfer pricing regulations have served as a model when China first started to regulate their transfer pricing, there are consequently similarities between the two.
Multinational corporations consider the issue of transfer pricing as the most important issue in their international taxation. It is important both from the aspect of being the most effective way to maximize the world profit of the corporation and also in the aspect that an adjustment due to inaccuracies in the corporation’s transfer prices can be expensive. The Chinese transfer pricing system is considered to be young in comparison with other jurisdictions, for example the United States. The Chinese government and its tax authorities have in recent years put a lot of effort in improving the transfer pricing system and its execution. Due to the amount of loss in tax revenue that is believed to be due to transfer pricing measures, the issue is considered to be of outmost importance.
The requirement on transfer pricing documentation has been an important issue for MNCs on the Chinese market, especially now when there is an interest levy on adjustments made through an audit. Since the current regulation on documentation is still quite vague, it constitutes an uncertainty for both taxpayers and tax authorities. However, an issuing of a clearer regulation on documentation requirements have long been anticipated but not yet released, although clarifying measures have been taken through the Corporate Income Tax Law and newly issued circulars during 2007.
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Kopecká, Jana. "Mezinárodní daňové plánování a optimalizace." Master's thesis, Vysoké učení technické v Brně. Fakulta podnikatelská, 2013. http://www.nusl.cz/ntk/nusl-224290.
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The diploma thesis focused on international tax planning and tax optimization. The diploma thesis specifies what is an international tax planning and underlines its importance in these days. On theoretical knowlege the diploma thesis summarizes key factors that should entrepreneurs in international tax planning and optimization to take into account. End of the thesis presents proposal the progress of the process of international tax planning and also on the particular case.
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Tichá, Dominika. "Vybrané daňové aspekty medzinárodného podnikania." Master's thesis, Vysoká škola ekonomická v Praze, 2014. http://www.nusl.cz/ntk/nusl-193862.
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The result of the global integration of the world economy are globally operating corporations. Multinational enterprises operate in different countries whose economic policies are different from each other. These differences have considerable impact on tax policy. Taxes are the subject of conflicting interests of the international business and tax policy. One of the current objectives of the MNEs is to reduce the total cost in order to achieving competitive advantage in the global market as well as to minimize the global tax liability through its optimization. To achieve these objectives the international tax planning is a widely used means. International tax planning uses tax havens and their favourable tax conditions to divert profits. Minimizing tax liability often leads to tax avoidance or tax evasion. Different legislative adjustments and mutual meeting of local and international legislation gradually uncover gaps and weaknesses enabling reduction and shedding of profits. Consequently, states are deprived of significant tax revenue. One of the most common and most important methods to minimize the tax liability of MNEs is transfer pricing. Transfer prices are to be determined in accordance with the arm's length principle, using comparative analysis and an appropriate method of assessment. Transactions carried out between associated enterprises may be regarded as a risk area which gets to the fore states and tax administrations. The first part of thesis focuses on tax policy in terms of international taxation of income and international tax planning. The second part presents a transfer pricing. The third and last part describes the practices of MNEs in transfer pricing and corresponding initiatives of national and international organizations.
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Mial, Fatima. "Fixation des prix de transfert à l'épreuve de la double imposition économique." Thesis, Aix-Marseille, 2014. http://www.theses.fr/2014AIXM1053.
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Avec la mondialisation, les groupes de sociétés ont multiplié les transactions internationales et, de fait, les phénomènes d'optimisation fiscale internationale. La nécessité de fixer des prix de transfert « objectifs » afin de permettre une juste répartition de la manne fiscale entre les États s'est très vite imposée. La remise en cause des prix de transfert conduit à une double imposition économique.Aujourd'hui, le principe de pleine concurrence est la norme internationale utilisée comme norme de référence pour la fixation de prix de transfert « objectifs ». Toutefois, cette norme est perfectible. Aussi, la communauté internationale cherche et expérimente des alternatives à la norme du prix du marché. Dès lors, les réglementations étatiques et internationales sont amenées à repenser la problématique des prix de transfert dans sa dimension économique et non plus dans un but exclusivement fiscal.L'évolution majeure de ces dernières années est la nouvelle approche de la relation administration fiscale/entreprise. L'entreprise doit fixer ses prix de transfert en accord avec l'administration pour réduire le risque de double imposition économique. Le souci d'assurer une juste répartition des recettes fiscales entre les États et de garantir la sécurité juridique au développement du commerce mondial, constituent les défis de demainAs a result of globalization, multinational companies have increased their international transactions, and in consequence, international tax planning. The need to determine "objective" transfer pricing in order to ensure the fair allocation of tax revenue between States quickly became a global necessity. However, the readjustment of transfer pricing as carried out by tax administrations leads to double taxation.At present, the arm's length principle is the international standard used as a reference norm to determine "objective" transfer pricing. However, this standard is perfectible and so the international community has been looking for and trying out alternatives to the norm of arm's length pricing. Consequently, both domestic and international rules and regulations need to be reassessed with regard to the problems of transfer pricing so that transfer pricing issues can be addressed not only from the perspective of tax revenue but also taking into account their overall economic dimension.The major evolution over last few years is the new approach to the tax administration/company relationship. The company must determine its transfer pricing in agreement with the tax administration in order to reduce the risk of economic double taxation. This aims to make sure that a fair share of income tax is apportioned between States and also guarantees a secure legal framework for the future allowing international trade to continue to develop and rise to meet the challenges that lie ahead
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Barry, Mamoudou. "Politiques fiscales et douanières en matière d'investissements étrangers en Afrique francophone : le cas du secteur des ressources naturelles extractives." Thesis, Normandie, 2019. http://www.theses.fr/2019NORMR060.
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Dès le début des années 1980, les États francophones d’Afrique, producteurs de matières premières, ont largement ouvert leur secteur extractif aux investissements étrangers. Cette ouverture a adopté plusieurs stratégies parmi lesquelles la fiscalité et les douanes ont occupé une place de choix. Nos travaux ont porté principalement sur ces dernières. En effet, l’enjeu de ces États a toujours été la conciliation de l’attractivité du secteur et sa rentabilité. Dans un premier temps, notre réflexion a été centrée sur les stratégies de mise en place des dispositifs fiscaux et douaniers de faveur et, dans un deuxième temps, sur la bonne gouvernance de ces dispositifs. Il ressort de nos travaux qu’au primo, si les stratégies fiscales et douanières ont réussi à attirer des investissements étrangers, la question de leur rentabilité est encore mitigée, ce pour de nombreuses raisons que nous avons analysées. C’est à ce niveau que nous avons fait des propositions d’amélioration. Au secundo, il apparaît que les conditions de la bonne gouvernance des dispositifs fiscaux et douaniers mis en place ne sont pas suffisamment réunies par les États francophones d’Afrique, d’où la nécessité de réunir ces dernières tout en améliorant les techniques de prévention et résolution des litigesSince the early 1980s, French-speaking African countries, producers of raw materials, have largely opened their extractive sector to foreign investments. This openness has adopted several strategies among which taxation and customs have occupied a special place. Our work focused on the latter. Indeed, the stakes of these states have always been the reconciliation of the attractiveness of the sector and its profitability. Initially, our reflection focused on the strategies for setting up favorable tax and customs systems and, secondly, on the good governance of these systems. Our research shows that, first, while tax and customs strategies have been successful in attracting foreign investments, the question of profitability is still mixed, for many reasons that we have analyzed. This is where we made suggestions for improvement. In the second, it appears that the conditions of good governance tax and customs arrangements put in place are not sufficiently met by Francophone African, hence the need reunite past and improve prevention and resolution techniques disputes
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Liesegang, Caterina [Verfasser], Marco [Akademischer Betreuer] Runkel, Marco [Gutachter] Runkel, and Thomas [Gutachter] Eichner. "Reforming multinational corporate income taxation in the European Union : the transition from separate accounting to formula apportionment from a tax competition perspective / Caterina Liesegang ; Gutachter: Marco Runkel, Thomas Eichner ; Betreuer: Marco Runkel." Berlin : Technische Universität Berlin, 2017. http://d-nb.info/1156272939/34.
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Johansson, Ida, and Josefine Delwér. "Transparens av skatt och internpriser : En del av företagens sociala ansvar?" Thesis, Högskolan i Borås, Akademin för textil, teknik och ekonomi, 2017. http://urn.kb.se/resolve?urn=urn:nbn:se:hb:diva-13036.
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I en konkurrenskraftig marknad söker sig multinationella företag till lågskatteländer för attmaximera vinsterna. Luckor i lagstiftningen samt utvecklingsländer som söker kapital harfrämjat att många multinationella företag bedriver strategier för att undvika eller undgåbeskattning. Dessa strategier är inget som företag väljer att presentera i deras årsredovisning.Det samma gäller de sociala konsekvenser som skatteplanering kan medföra. Det finns delademeningar huruvida företagens beskattning borde ses som en del av företagens ansvar. Syftetmed studien är därför att lyfta fram hur transparenta multinationella företag är i sinårsredovisning kring beskattning och internprissättning till följd av skärpta riktlinjer. Baseratpå rekommendationerna i BEPS action 13 vill vi skapa en medvetenhet i hur bristandetransparens av beskattning samt internprissättning hos multinationella företag kan ses som ettCSR-problem. Studien grundar sig i en tvärsnittsstudie med en kvalitativ ansats. Genom eninnehållsanalys har vi samlat in datamaterial i form av årsredovisningar från ett urval av sexmultinationella företag. Utifrån den teoretiska referensramen har empirin analyserats vilkethar gett en förståelse huruvida företagen är transparenta kring sin beskattning ochinternprissättning. Resultatet visade på att det fanns en variation huruvida företag ärtransparenta i sin årsredovisning, generellt sätt höll sig samtliga företag på en låg nivå avtransparens. Vi kan konstatera att samtliga företag uttryckte att beskattningen utsatteföretagen för en riskexponering. Ett flertal av företagen uttryckte vidtagna åtgärder i och medimplementeringen av BEPS action 13, ändå var det bara två företag som såg beskattningensom en del av CSR.In a competitive market, multinational companies are using low-tax countries to maximizetheir profits. Gaps in the legislation and developing countries searching for capital are twofactors why many multinational companies are undertaking strategies to avoid taxation. Thesestrategies are not disclosed in their annual report. The same applies to the social consequencesthat tax planning can entail. There are divided opinions whether corporate taxation should beseen as part of the corporate responsibility. The purpose of the study is therefore to highlightwhether multinational companies are transparent in their annual report regarding taxation andtransfer pricing as a result of new guidelines. Based on the recommendations in BEPS action13, the study aims to raise awareness of how insufficient transparency of taxation as well astransfer pricing of multinational companies can be seen as a CSR problem. The study is basedon a cross-sectional method with a qualitative approach. Through a content analysis data wascollected in the form of annual reports on a selection of six multinational companies. Basedon the theoretical framework, the empirical study has been analysed in order to determinewhether the companies are transparent about taxation and transfer pricing. The result showedthat generally all companies held a low level of transparency within their annual reports.However, all companies expressed that the taxation exposed the companies to a risk. Amajority of the companies expressed taking action as a result of the implementation of BEPSaction 13. However, only two companies saw the taxation as part of CSR.This thesis will continue in Swedish.
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Braun, Julia, and Alfons Weichenrieder. "Does Exchange of Information between Tax Authorities Influence Multinationals' Use of Tax Havens?" WU Vienna University of Economics and Business, Universität Wien, 2015. http://epub.wu.ac.at/4482/1/SSRN%2Did2569624.pdf.
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Since the mid-1990s, countries offering tax systems that facilitate international
tax avoidance and evasion have been facing growing political pressure to comply
with the internationally agreed standards of exchange of tax information. Using
data of German investments in tax havens, we find evidence that the conclusion
of a bilateral tax information exchange agreement (TIEA) is associated with
fewer operations in tax havens and the number of German affiliates has on
average decreased by 46% compared to a control group. This suggests that firms
invest in tax havens not only for their low tax rates but also for the secrecy they
offer. (authors' abstract)Series: WU International Taxation Research Paper Series
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Loose, Thomas. "Tax-Management der kapitalmarktorientierten internationalen Unternehmung." Lohmar Köln Eul, 2009. http://d-nb.info/999286676/04.
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Pellefigue, Julien. "Théorie économique de la réglementation des prix de transfert." Thesis, Paris 2, 2012. http://www.theses.fr/2012PA020047/document.
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Le terme de « prix de transfert » désigne le prix des transactions conclues entre les filiales d’une même entreprise multinationale. La thèse traite, sous un angle essentiellement normatif, de la problématique de réglementation de ces prix, c'est-à-dire de la détermination du mode de partage optimal du profit d’un groupe entre ses filiales. La thèse s’attache tout d’abord à montrer l’effet de la réglementation des prix de transfert sur les décisions de production et d’investissement des entreprises, puis sur le bien-être mondial. Sur la base des résultats obtenus, les objectifs qu’un dictateur bienveillant international devrait assigner à ce type de réglementation sont ensuite établis. Ce double travail permet de tracer le contour d’un projet de réglementation optimale, fondé sur le concept d’équité inter-nations, et dont l’application conduirait à attribuer à chaque filiale sa valeur de Shapley dans un jeu préalablement défini. La thèse éclaire également le débat contemporain en proposant un protocole permettant de comparer le principe de pleine concurrence avec la méthode d’allocation forfaitaireThe prices of the transactions set between subsidiaries of a multinational corporation are usually called « transfer prices ». The dissertation deals with the normative questions raised by the regulation of such prices, particularly the optimal way of distributing the profit of a multinational between its subsidiaries. The dissertation first shows how the transfer prices regulation can influence corporate production and investment decisions, thereby impacting worldwide welfare. Based upon these results, the objectives that an international benevolent dictator would pursue through such a regulation are then identified. This program allows for the sketching of an optimal transfer prices regulation, which relies strongly upon the inter-nation equity concept, and which application would grant each subsidiary its Shapley value in a certain game. The dissertation also makes a contribution to the current debate by proposing a protocol to compare the arm’s length principle with the formulary apportionment method
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Daily, Robert L. "Avoiding Taxes On Foreign Profits: How To Fix the Games That Multinationals Play." Scholarship @ Claremont, 2012. http://scholarship.claremont.edu/cmc_theses/517.
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The current United States tax code regarding foreign sourced income is outdated for a heavily globalized and interconnected world. Multinationals have played certain games with the tax code to lower their domestic and foreign tax bill. This form of tax avoidance has real economic effects that are leading to non-optimal economic outcomes. This paper will begin by offering examples of how multinationals are avoiding taxes, especially in the pricing of intangible assets. Other countries have adopted different ways to tax foreign profits; notably most countries either have a worldwide non-deferral tax system or a territorial tax system. There are costs and benefits associated with both systems of taxation that must be considered before adoption. Ultimately, this paper will conclude that a territorial tax system combined with an overhaul of the current rules regarding transfer pricing will lead to a better economic outcome than the current U.S. system of taxation.
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Mberi, Faith Chipiwa. "Addressing challenges facing SARS relating to the application of transfer pricing in business restructurings / Faith Chipiwa Mberi." Thesis, North-West University, 2012. http://hdl.handle.net/10394/8723.
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Multinational enterprises have been widely accused of using aggressive tax planning schemes to avoid paying tax all over the world. The purpose of this study is to analyse the methods used by multinational enterprises in the context of business restructurings to shift profits from high to low tax jurisdictions. Transactions between associated entities have generally been manipulated by applying non-arm’s length prices to these transactions, as well as devising agreements where the economic substance varies from the form of the transaction. The study aims to investigate some of the practical challenges faced by tax administrators in the application of the arm’s length principle.
The study was conducted based on a literature review, as well as analysing specific examples reported in newspapers where multinational enterprises have used aggressive tax planning schemes to shift profits. International case law was also analysed to evaluate some of the factors considered by the courts in the determination of the arm’s length price.
It was found that multinational enterprises definitely use aggressive tax planning schemes to shift profits. The practical challenges in the determination of arm’s length prices, complexity of the transactions involved, as well as a lack of resources, especially in the developing nations, are some of the factors that cause tax administrators to battle to find a solution to deter and detect these schemes. Other methods such as the unitary taxation method and the country by country reporting concept have been brought forward as alternatives to the arm’s length principle.
These alternatives have been proposed in an effort to find a solution to the challenges posed by the arm’s length principle. Specific measures have also been recommended for developing nations’ tax administrators to resolve the issues that they currently experience in this context.Thesis (MCom (South African and International Taxation))--North-West University, Potchefstroom Campus, 2013
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Lang, Michael, and Jeffrey Owens. "The Role of Tax Treaties in Facilitating Development and Protecting the Tax Base." WU Vienna University of Economics and Business, Universität Wien, 2014. http://epub.wu.ac.at/4094/1/SSRN%2Did2398438.pdf.
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The amount of taxes paid by multinational enterprises (MNEs) in host and home
countries continues to make headline news. Corporate tax regimes, particularly those in
many OECD countries, have never been more complex and the competition to attract and
retain foreign direct investment (FDI) has perhaps never been so great. All of these
political, legal, economic and competitive realities face countries at a time when they
need additional budget revenues.
At the June 2012 G-20 Summit in Los Cabos, leaders identified base erosion and profit
shifting as key fiscal issue to be addressed. Many are expecting this to translate into a
new approach to applying existing international tax standards, an increased pressure to
eliminate "corporate tax breaks", enact tougher anti-abuse provisions, and less tolerance
of aggressive tax planning.
There has been an increased critical focus on transfer pricing, corporate restructuring and
double tax treaties. Some have suggested that double tax treaties are eroding the
domestic tax bases of developing countries, while others conclude that double tax
treaties promote development and FDI and thereby expand the tax base. Dividing up a
"revenue pie" has never been easy and the implementation of international tax rules to
transparently and predictably allocate revenue to avoid double taxation and double non
taxation has never been more adversarial between taxpayers and tax authorities and
between tax jurisdictions.
It was for these reasons that the Global Tax Policy Center of the Institute for Austrian
and International Tax Law (Vienna University of Economics and Business) and the
International Tax and Investment Center (ITIC) decided to undertake this study. The
objective of our study was to look at the development impact of double taxation treaties
and, more broadly, how tax policy can help generate economic growth and
prosperity. Legally domestic tax laws are normally subordinate to international double
taxation treaties, but in reality a double tax treaty only serves a country as well as its
domestic tax regime.
We've concluded that the problems affecting developing countries lie not with double tax
treaties but rather in weak domestic tax legislation. Our study reviews empirical data
from 20 developing countries, including LDCs, middle-to-high income developing
countries, resource-rich countries, and BRIICS[1] countries.
We hope that the empirical analysis and the conclusions that can be drawn from it can
help guide policymakers to refocus their policy objectives to boost capital formation,
expanding exports, and protect their domestic tax bases. We believe that a country with
strong domestic tax legislation can advance their pursuit of the Millennium Development
Goals by affectively utilizing double tax treaties and the related international tax rules to
more transparently share and grow their tax base. (authors' abstract)Series: WU International Taxation Research Paper Series
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Ortmann, Regina, and Erich Pummerer. "Formula Apportionment or Separate Accounting? Tax-Induced Distortions of Multinationals' Location Investment Decisions." WU Vienna University of Economics and Business, Universität Wien, 2015. http://epub.wu.ac.at/4703/1/SSRN%2Did2688090.pdf.
Full textAbstract:
We examine which tax allocation system leads to more severe distortions with respect to locational
investment decisions. We consider separate accounting (SA) and formula apportionment (FA). The
effects of both systems have been hotly debated in Europe in the past years. The reason is that the EU
Member States are striving to implement a common European tax system that would lead to a switch
from SA to FA. While existing studies focus primarily on the impact of taxes on locational decisions
under either SA or FA, the main innovation of this paper is that it compares both systems with regard
to the level of distortions they induce. We compare the optimal pre-tax investment decision with the
optimal after-tax investment decision and infer from the difference in the allocation of investment
funds which tax allocation system causes more severe distortions. We assume that the multinational
group (MNG) has comprehensive book income shifting opportunities under SA. We find that the
investment incentives under SA are opposed to those under FA for a profitable investment project.
Whereas under SA as much as possible should be invested in a high-tax country, under FA as much as
possible should be invested in a low-tax country. The distortions of locational investment decisions
tend to be more severe under SA than under FA if a greater share of investment funds is to be invested
in a low-tax country from a pre-tax perspective and the investment is profitable. Vice versa, locational
decisions may be more distorted under FA if the optimal pre-tax investment decision requires
investing a major share of funds in the high-tax country. In contrast to the often stated insensitivity of
FA towards income shifting, we find the introduction of a tax allocation system based on FA in
Europe could lead to a severe shift of economic substance to low-tax countries. The results of this
paper are of particular interest for European policy makers and MNGs as our findings may induce
European MNGs to reassess their recent locational investment decisions in the face of a potential
future change in the applied tax allocation system. (authors' abstract)Series: WU International Taxation Research Paper Series
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Bénassy-Quéré, Agnès. "Détermination des taux de change dans un modèle macroéconomique multinational." Paris 9, 1992. https://portail.bu.dauphine.fr/fileviewer/index.php?doc=1992PA090012.
Full textAbstract:
Nous étudions les interactions entre l'économie réelle et les taux de change, dans le but de comprendre comment, dans un modèle macroéconomique multinational, l'ajustement des parités modifie la réaction des économies aux chocs. Les théories du taux de change se vérifient mal empiriquement. Mais les tests sont eux-mêmes incertains. Les anticipations jouent un rôle central dans les modèles de change, l'hypothèse d'anticipations semi-rationnelles paraît la mieux adaptée dans un modèle macroéconomique de grande taille, pour des raisons à la fois de cohérence, de facilité de résolution et de stabilité. Les modèles d'option sont plus réalistes, mais partiellement incohérents et facilement instables. Les propriétés d'un modèle macroéconomique financièrement intégré dépendent aussi de la forme de la politique monétaire et des comportements patrimoniaux. Sur le plan empirique, les modèles de portefeuille sous forme structurelle s'avèrent instables lorsqu'ils respectent l'économétrie, même avec une spécification stabilisante des taux d'intérêt. Nous choisissons tout de même cette approche pour sa description explicite des comportements d'arbitrage entre actifs. Cependant nous calibrons partiellement les équations de façon à les rendre utilisables une fois intégrées dans le modèle Mimosa. Les taux d'intérêt sont déterminés par des fonctions de réaction. L'introduction de taux d'intérêt et de taux de change endogènes modifie considérablement les propriétés de Mimosa. Les variantes sont conformes aux attentes théoriques, avec quelques écarts dus aux caractéristiques du modèle réel et à la diversité des monnaies en jeuWe study interactions between exchange rates and the real economy. The aim is to understand how, in a multicounty model, the behavior of economies is affected by exchange rate adjustment. There is little evidence for exchange rate theories. However, tests themselves are questionable. Expectations play a central part in exchange rate models. The semi-rational assumption seems to be the most suited to a large macroeconomic model, for reasons of consistency, computation and stability. Opinion models are more realistic, but hardly consistent and often destabilizing. The properties of a financially-integrated model rely also on the design of the monetary policy and of capital flows. Turning to the empirical side, structural portfolio models prove out to be unstable when econometric estimates are used, even with a stabilizing specification for interest rates. Nevertheless, we choose this approach for its explicit description of arbitrages. But restrictions are imposed in order not to destabilize the mimosa model. Interest rates follow reaction functions. Mimosa's properties are largely modified when endogenous interest rates and exchange rates are introduced. Simulations are in line with theoretical results, with a few differences due to the real model features and to the variety of devices included
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Castel-Branco, João Amaro dos Santos. "Essay about European Union’s tax competitiveness." Master's thesis, Instituto Superior de Economia e Gestão, 2019. http://hdl.handle.net/10400.5/19953.
Full textAbstract:
Mestrado em FinançasA competitividade fiscal entre Estados Membros, traz potenciais benefícios para as multinacionais aos quais não são acessíveis às empresas domésticas, criando uma vantagem competitiva não natural. Esses benefícios podem ser traduzidos pela redução de taxas de imposto sobre lucros e/ou por um conjunto de regras fiscais que permitem a canalização e alocação de tais lucros, através de royalties, juros e preços de transferência para territórios com menor carga tributária. A problemática está não só quando estimula uma distorção da concorrência entre empresas multinacionais e domésticas, mas também para o comum contribuinte europeu que deve suportar a soma das receitas públicas perdidas com a evasão fiscal legal. O estudo tem como objetivo verificar se os argumentos para a competitividade fiscal são significantes. Tendo uma abordagem diferente de estudos similares anteriores, pretende comparar dois diferentes indicadores de competitividade fiscal. Um indicador já estudado e testado (taxas de imposto representado a carga fiscal) e outro criado através de um questionário feito a especialistas do sistema fiscal de cada estado membro. Para além de confirmar a maioria das conclusões da literatura anterior, o estudo conclui que os argumentos à competitividade fiscal estão, de um modo geral, mais fortemente correlacionados com o novo indicador do que com a carga fiscal. Mesmo devido a limitações dos dados, o estudo sugere o novo indicador como bom indicador de competitividade fiscal.
Tax competitiveness between member states brings potential benefits to multinationals, not accessible to domestic firms. It creates an unnatural competitive advantage. These benefits can be translated into reduced tax rates on profits and/or by a set of tax rules that allows the channeling and allocation of such income (via royalties, interest and transfer prices) to territories with a lower tax burden. It becomes a problem not only when it stimulates a distortion of competition among MNEs and domestics but also for the common European taxpayer that must cope the sum of public revenue lost to legal tax avoidance. Because of the great amounts at stake and relatively new types of business model, the theme is a cooperation challenge in EU. The study aims to verify if the arguments for tax competitiveness are significant. Taking a different approach from previous similar studies, it intends to compare two different indicators of fiscal competitiveness. An indicator already studied and tested (tax rates as tax burden representative) and, and indicator created through a questionnaire, made to specialists of the of each member states tax system. In addition to confirming most of the conclusions of previous literature, the study concludes that the arguments for fiscal competitiveness are generally more strongly correlated with the new indicator than with the tax burden. So, even with data limitations, the study suggests the new indicator as a good indicator of fiscal competitiveness
info:eu-repo/semantics/publishedVersion
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角田, 伸広, and Nobuhiro TSUNODA. "移転価格税制における多国籍企業への独立企業原則適用の困難性とその解決 : 租税訴訟での課題と租税条約上の相互協議での解決可能性の考察." Thesis, 一橋大学, 2011. http://hdl.handle.net/10086/23221.
Full text
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Gibson, Candice Mary. "The effectiveness of anti-avoidance provisions and the global initiatives created to prevent multinationals avoiding tax." Diss., University of Pretoria, 2018. http://hdl.handle.net/2263/65651.
Full textAbstract:
Tax structuring arrangements resulting in the shifting of profits by Multinationals has become increasingly relevant, with Multinationals such as Starbucks, Amazon, Google and MTN amongst others, coming under scrutiny by tax authorities. Multinationals are being challenged in respect of these tax avoidance strategies adopted in order to pay as little tax as possible. In the UK for example, the accounts of Starbucks have shown that since 1998, Starbucks has obtained approximately £3 billion from its UK coffee sales, opened seven hundred and thirtyfive outlets throughout the UK, but paid only £8.6 million in income taxes. Despite the measures undertaken by Multinationals to avoid paying taxes, or paying limited taxes, these Multinationals have maintained that they have not avoided tax as they have complied with the tax legislation in the countries in which they operate and transact. The loss of revenue for the fiscus as a result of the Multinationals avoiding paying taxes in the countries in which they operate could have serious consequences, and it is the responsibility of the legislators to enact or amend legislation, or to create frameworks to prevent tax avoidance taking place. This study research is aimed at the analysis of the general anti-avoidance provisions found in South Africa and in the UK in order to ascertain whether these provisions have been an effective deterrent against tax avoidance by Multinationals. In addition, this study will further provide an insight into the BEPS current global framework, which aims to equip governments with the domestic and international instruments required to tackle BEPS in an attempt to prevent Multinationals from shifting their profits to low or no tax jurisdictions. this study is whether the newly established GAAR provisions.Mini Dissertation (LLM)--University of Pretoria, 2018.
Mercantile Law
LLM
Unrestricted
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Nakamoto, Tembo. "The International Tax System in the Digitalized Economy Studied from the Viewpoints of Network Science and Policy Processes." Doctoral thesis, Kyoto University, 2021. http://hdl.handle.net/2433/263805.
Full textAbstract:
付記する学位プログラム名: 京都大学大学院思修館京都大学
新制・課程博士
博士(総合学術)
甲第23344号
総総博第17号
京都大学大学院総合生存学館総合生存学専攻
(主査)教授 池田 裕一, 特定教授 武田 英俊, 教授 諸富 徹
学位規則第4条第1項該当
Doctor of Philosophy
Kyoto University
DFAM
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Prost, Benjamin de. "Les deux formes d' IDE et l'investissement productif : l'impact du taux de change réel." Thesis, Paris 2, 2012. http://www.theses.fr/2012PA020096/document.
Full textAbstract:
Dans ce travail, nous analysons et comparons les comportements de localisation de trois différentes formes d'investissements durables (les greenfields seuls, les investissements directs étrangers totaux (IDE) et les investissements productifs intérieurs). Parmi un groupe de déterminants, dont une large partie est inspirée de la littérature empirique existante, nous étudions tout particulièrement le rôle que joue le taux de change réel sur l'attractivité des territoires vis-à-vis de chacun de ces investissements. Un tel examen est opéré à partir d'une économétrie de données de panel. Il consiste à tester un modèle de référence sur les greenfields, les IDE totaux ainsi que sur les investissements productifs – avec des spécifications adaptées à chaque cas – et à interpréter l'ensemble des résultats et en particulier les écarts obtenus. Pour appréhender les variables dépendantes, nous nous appuyons sur les séries statistiques de la CNUCED et de l'OCDE, ainsi que sur celles du FDI Markets (Financial Times), et de l'European Investment Monitor (Ernst & Young) qui ont jusqu'à présent été peu exploitées, voire ignorées, par les études portant sur le sujet. Plusieurs échantillons (global, européen et OCDE) et plusieurs périodes (2004-2010, 1998-2010, 1995-2010) sont retenus en fonction de la disponibilité des données. Nos résultats indiquent que les greenfields, les IDE totaux (et donc, par déduction, les fusions-acquisitions) et les investissements productifs répondent à des critères de localisation bien différents correspondant à leurs caractéristiques propres. L'impact qu'exerce notamment le taux de change réel sur chacun de ces capitaux est des plus intéressants. De faibles prix relatifs apparaissent ainsi comme attirant de façon sensible les investissements productifs, qu'ils soient d'origine domestique ou étrangère (greenfields). En revanche, il semble que ces prix relatifs n'aient aucune influence sur les recompositions transnationales de capital, déduites à partir des IDE totauxIn this work, we analyze and compare locational behavior of three forms of durable investments (greenfields, foreign direct investments, and internal productive investments). Among a group of determinants, mainly inspired by the existing empirical literature, we study more particularly the role played by the real exchange rate on countries' attractiveness towards each of those investments. Panel data econometrics is used for this study. We test a basis model on greenfields, total FDIs, and on productive investments – with specifications adapted to each case – and then analyze the results, particularly when they show differences. In order to proxy the dependent variables, we use the UNCTAD and the OECD's data series, as well as the FDI Markets (Financial Times) and the European Investment Monitor (Ernst & Young) which have somehow been ignored by the studies on the subject until now. Several samples (global, European and OECD) and several periods (2004-2010, 1998-2010 and 1995-2010) are analyzed depending on data availability. Our results prove that greenfields, total FDIs (and mergers and acquisitions by deduction), and productive investments respond to different location criteria according to their characteristics. In particular, the impact of the real exchange rate on each of those investments is very interesting. While low relative prices attract significantly productive investments, financed by domestic or foreign multinational companies (greenfields), they don't seem to have any impact on mergers and acquisitions (deduced from total FDIs)