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Income Shifting From Transfer Pricing
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Book Synopsis Income Shifting from Transfer Pricing by : Michael McDonald
Download or read book Income Shifting from Transfer Pricing written by Michael McDonald and published by CreateSpace. This book was released on 2015-01-01 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: The paper updates, modifies, and extends research by Grubert (2003) to investigate income shifting from intercompany transfer pricing. The analysis is based on theoretical and regression models developed in Grubert (2003). The models are modified slightly to capture the effects of "real" intercompany tangible, intangible, and services transactions (as opposed to interest 'income stripping' through intercompany or interbranch debt), and extended to incorporate data relating to cost sharing arrangements. Although some caution is required in interpreting the transfer pricing implications from the regression results, the empirical analysis generally supports concerns about potential non-arm's length income shifting under current transfer pricing rules.
Book Synopsis Addressing Base Erosion and Profit Shifting by : OECD
Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
Book Synopsis Why is There Corporate Taxation in a Small Open Economy? by : Roger H. Gordon
Download or read book Why is There Corporate Taxation in a Small Open Economy? written by Roger H. Gordon and published by . This book was released on 1994 with total page 22 pages. Available in PDF, EPUB and Kindle. Book excerpt: Several recent papers argue that corporate income taxes should not be used by small, open economies. With capital mobility, the burden of the tax falls on fixed factors (e.g., labor), and the tax system is more efficient if labor is taxed directly. However, corporate taxes not only exist but rates are roughly comparable with the top personal tax rates. Past models also forecast that multinationals should not invest in countries with low corporate tax rates, since the surtax they owe when profits are repatriated puts them at a competitive disadvantage. Yet such foreign direct investment is substantial. We suggest that the resolution of these puzzles may be found in the role of income shifting, both domestic (between the personal and corporate tax bases) and cross-border (through transfer pricing). Countries need cash-flow corporate taxes as a backstop to labor taxes to discourage individuals from converting their labor income into otherwise untaxed corporate income. We explore how these taxes can best be modified to deal as well with cross-border shifting.
Book Synopsis Taxes and Transfer-pricing by : John Jacob
Download or read book Taxes and Transfer-pricing written by John Jacob and published by . This book was released on 1995 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Fundamentals of International Transfer Pricing in Law and Economics by : Wolfgang Schön
Download or read book Fundamentals of International Transfer Pricing in Law and Economics written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2012-02-15 with total page 308 pages. Available in PDF, EPUB and Kindle. Book excerpt: The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm’s length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Book Synopsis The Multilateral Convention on Mutual Administrative Assistance in Tax Matters Amended by the 2010 Protocol by : OECD
Download or read book The Multilateral Convention on Mutual Administrative Assistance in Tax Matters Amended by the 2010 Protocol written by OECD and published by OECD Publishing. This book was released on 2011-06-01 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication contains the official text of the Multilateral Convention on Mutual Assistance in Tax Matters as amended by the 2010 Protocol.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Documentation and Country-by-Country Reporting by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Documentation and Country-by-Country Reporting written by OECD and published by OECD Publishing. This book was released on 2014-09-16 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: This document contains revised standards for transfer pricing documentation and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity.
Book Synopsis Why is There Corporate Taxation in a Small Open Economy? The Role of Transfer Pricing and Income Shifting by : Roger H. Gordon
Download or read book Why is There Corporate Taxation in a Small Open Economy? The Role of Transfer Pricing and Income Shifting written by Roger H. Gordon and published by . This book was released on 2009 with total page 35 pages. Available in PDF, EPUB and Kindle. Book excerpt: Several recent papers argue that corporate income taxes should not be used by small, open economies. With capital mobility, the burden of the tax falls on fixed factors (e.g., labor), and the tax system is more efficient if labor is taxed directly. However, corporate taxes not only exist but rates are roughly comparable with the top personal tax rates. Past models also forecast that multinationals should not invest in countries with low corporate tax rates, since the surtax they owe when profits are repatriated puts them at a competitive disadvantage. Yet such foreign direct investment is substantial. We suggest that the resolution of these puzzles may be found in the role of income shifting, both domestic (between the personal and corporate tax bases) and cross-border (through transfer pricing). Countries need cash-flow corporate taxes as a backstop to labor taxes to discourage individuals from converting their labor income into otherwise untaxed corporate income. We explore how these taxes can best be modified to deal as well with cross-border shifting.
Book Synopsis Fundamentals of Transfer Pricing by : Michael Lang
Download or read book Fundamentals of Transfer Pricing written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2021-06-18 with total page 484 pages. Available in PDF, EPUB and Kindle. Book excerpt: Transfer pricing is one of the most relevant and challenging topics in international taxation. Over the last century, nearly every country in the world introduced transfer pricing rules into their domestic legislation. Indeed, it was estimated that profit shifting generated by the improper application of transfer pricing rules has resulted in global tax losses worth USD 500 billion for governments – 20% of all corporate tax revenues. It is thus imperative that all tax professionals thoroughly understand the nature of transfer pricing and how the growing body of applicable rules works in practice. In this crucially significant volume, stakeholders from government, multinational companies, international organisations, advisory groups and academia offer deeply informed perspectives, both general and specific, on the practical application of transfer pricing rules, taking into consideration all the most recent developments. With approximately 160 practical examples and 90 relevant international judicial precedents, the presentation proceeds from general to more specialised topics. Such aspects of the subject as the following are thoroughly analysed: what is transfer pricing and the purpose of transfer pricing rules; the arm’s length principle and its application; the consequences of a transaction not being in accordance with the arm’s length principle; the transfer pricing methods; the mechanisms to avoid and resolve disputes; the transfer pricing documentation; the attribution of profits to permanent establishments; the transfer pricing aspects of specific transactions, such as services, financing, intangibles and business restructurings. The application of transfer pricing legislation is arguably the most difficult task that taxpayers and tax authorities around the world must face. With this authoritative source of practical guidance, government officials, tax lawyers, in-house tax counsel, academics, advisory firms, the business community and other stakeholders worldwide will have all the detail they need to move forward in tackling this thorny aspect of the current tax environment.
Book Synopsis Present Law and Background Related to Possible Income Shifting and Transfer Pricing by : United States. Congress. Joint Committee on Taxation
Download or read book Present Law and Background Related to Possible Income Shifting and Transfer Pricing written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 2010 with total page 132 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Crisis in Tax Administration by : Henry Aaron
Download or read book The Crisis in Tax Administration written by Henry Aaron and published by Rowman & Littlefield. This book was released on 2004-05-20 with total page 420 pages. Available in PDF, EPUB and Kindle. Book excerpt: People pay taxes for two reasons. On the positive side, most people recognize, even if grudgingly, that payment of tax is a duty of citizenship. On the negative side, they know that the law requires payment, that evasion is a crime, and that willful failure to pay taxes is punishable by fines or imprisonment. The practical questions for tax administration are how to strengthen each of these motives to comply with the law. How much should be spent on enforcement and how should enforcement be organized to promote these objectives and achieve the best results per dollar spent? Over the last few years, the U.S. Congress has restricted spending on tax administration, forcing the Internal Revenue Service to curtail enforcement activities, at the same time, that the number of individual filers has increased, tax rules have become more complex, and more business have become multinational operations. But if too many cases of tax evasion go undetected and unpunished, those who may have grudgingly paid their taxes may soon find it easier to join the scofflaws. These events in combination have created a genuine crisis in tax administration. The chapters in this volume evaluate the capacity of authorities to enforce the tax laws in a modern, global economy and examine the implications of failing to do so. Specific aspects of tax law, including tax shelters, issues relating to small businesses, tax software, role of tax preparers, and the objectives of tax simplification are examined in detail. The volume also builds a conceptual basis for future scholarship, with regard not only to tax administration, but also to such fundamental questions as whether taxpayers respond mostly to economic incentives or are influenced by their experiences with the filing process and what is the proper framework for evaluating the allocation of resources within the IRS.
Book Synopsis International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots by : Sebastian Beer
Download or read book International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots written by Sebastian Beer and published by International Monetary Fund. This book was released on 2018-07-23 with total page 45 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
Book Synopsis Transfer Pricing Aspects of Intra-Group Financing by : Raffaele Petruzzi
Download or read book Transfer Pricing Aspects of Intra-Group Financing written by Raffaele Petruzzi and published by Kluwer Law International B.V.. This book was released on 2013-10-20 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: For corporate managers, maximization of the profits and the market value of the firm is a prime objective. The logical working out of this principle in multinational enterprises has led to an intense focus on transfer pricing between related companies, principally on account of the very attractive tax advantages made possible. Inevitably, numerous countries have established transfer pricing legislation designed to combat the distortions and manipulations that are inherent in such transactions. This important book, one of the first in-depth analysis of the current worldwide working of transfer pricing in intra-group financing and its resonance in law, presents the relevant issues related to loans, financial guarantees, and cash pooling; analyses an innovative possible approach to these issues; and describes new methodologies that can be implemented in practice in order to make intra-group financing more compliant with efficient corporate financing decisions and the generally accepted OECD arm’s length principle. Comparing the tax measures implemented in the corporate tax law systems of forty countries, this study investigates such aspects of intra-group financing as the following: – corporate finance theories, studies, and surveys regarding financing decisions; – application of the arm’s length principle to limit the deductibility of interest expenses; – impact of the OECD’s Base Erosion and Profit Shifting (BEPS) project; – transfer pricing issues related to intra-group financing; – credit risk in corporate finance; – rationales utilized by credit rating agencies; and – the assessment of arm’s length nature of intra-group financing. The author describes ways in which the application of the arm’s length principle can be strengthened and how the related risk of distortion and manipulation can be minimized. The solutions and methodologies proposed are applicable to any business sector. Given that determination of the arm’s length nature of transactions between related companies is one of the most difficult tasks currently faced by taxpayers and tax administrations around the world, this thorough assessment and analysis will prove extraordinarily useful for in-house and advisory practitioners, corporate officers, academics, international organizations, and government officials charged with finding effective responses to the serious issues raised. In addition to its well-researched analysis, the book’s comparative overview of how loans, financial guarantees, and cash pooling are currently addressed by OECD Member States and by their national courts is of great practical value in business decision making.
Book Synopsis Do Transfer Pricing Laws Limit International Income Shifting? Evidence from European Multinationals by : Theresa Lohse
Download or read book Do Transfer Pricing Laws Limit International Income Shifting? Evidence from European Multinationals written by Theresa Lohse and published by . This book was released on 2013 with total page 30 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Aspects of Intangibles by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Aspects of Intangibles written by OECD and published by OECD Publishing. This book was released on 2014-09-16 with total page 134 pages. Available in PDF, EPUB and Kindle. Book excerpt: This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles.
Book Synopsis Income Shifting Under Losses by : Arnt O. Hopland
Download or read book Income Shifting Under Losses written by Arnt O. Hopland and published by . This book was released on 2014 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis At A Cost: the Real Effects of Transfer Pricing Regulations by : Ruud A. de Mooij
Download or read book At A Cost: the Real Effects of Transfer Pricing Regulations written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2018-03-23 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt: Unilateral adoption of transfer pricing regulations may have a negative impact on real investment by multinational corporations (MNCs). This paper uses a quasi-experimental research design, exploiting unique panel data on domestic and multinational companies in 27 countries during 2006-2014, to find that MNC affiliates reduce their investment by over 11 percent following the introduction of transfer pricing regulations. There is no significant reduction in total investment by the MNC group, suggesting that these investments are most likely shifted to affiliates in other countries. The impact of transfer pricing regulations corresponds to an increase in the ``TPR-adjusted'' corporate tax rate by almost one quarter.
