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Author : Arnt O. Hopland
Publisher :
ISBN 13 :
Total Pages : 42 pages
Book Rating : 4.:/5 (97 download)
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:
Author : Arnt Hopland
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (13 download)
Download or read book Flexibility in Income Shifting Under Losses written by Arnt Hopland and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This study examines the flexibility of multinational firms to adjust their income-shifting strategies -- whether using transfer pricing or internal debt -- during the tax year to react to affiliates' operating losses. We develop the concept that under flexibility, multinationals can adjust their inter-affiliate payments ex post (i.e., after financial outcomes are revealed, but before the end of the tax year), to minimize worldwide tax payments. Without flexibility, multinationals must commit to their affiliates' income-shifting strategies ex ante (i.e., before financial outcomes are revealed). Our central prediction is that under ex-post income shifting, loss affiliates report lower transfer prices and internal leverage than profitable affiliates; under ex-ante income shifting, affiliates report the same transfer prices and internal capital structure, regardless of making losses. Using novel data on direct transfer payments and internal debt of Norwegian affiliates, we find empirical evidence that transfer pricing, particularly related to user fees, but not internal debt, provides flexibility to adjust income shifting ex post. In additional tests, we confirm that our results reflect flexibility rather than loss affiliates' poor performance. Our study should interest tax policymakers and researchers by identifying how various mechanisms allow multinational firms to shift income when they face losses.
Author : Arnt Hopland
Publisher :
ISBN 13 :
Total Pages : 42 pages
Book Rating : 4.:/5 (13 download)
Download or read book Implications of Flexibility in Income Shifting Under Losses written by Arnt Hopland and published by . This book was released on 2019 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study develops theory and discusses implications of flexibility in income shifting for multinational corporations that have both profit- and loss-making affiliates. Our theoretical model shows that when multinationals do not have flexibility to adjust their income-shifting strategies within a tax year in response to losses (i.e., they must implement 'ex-ante' income-shifting strategies), they take the expected loss-adjusted tax rate differential into account rather than the larger statutory tax rate differential. This central finding suggests that prior empirical studies using the statutory tax rate differential risk underestimating the tax sensitivity of income shifting. We also find that flexibility to adjust income-shifting strategies to losses has important implications for how and why the profit distribution of multinationals' affiliates differs from domestic corporations: Under inflexibility, some affiliates will form a fat tail in the loss part of the distribution. Finally, we provide guidance for future empirical work based on our theoretical predictions.
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264192743
Total Pages : 91 pages
Book Rating : 4.2/5 (641 download)
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.
Author : Myron S. Scholes
Publisher :
ISBN 13 : 9781292065571
Total Pages : 528 pages
Book Rating : 4.0/5 (655 download)
Download or read book Taxes and Business Strategy written by Myron S. Scholes and published by . This book was released on 2015-01-03 with total page 528 pages. Available in PDF, EPUB and Kindle. Book excerpt: For MBA students and graduates embarking on careers in investment banking, corporate finance, strategy consulting, money management, or venture capital Through integration with traditional MBA topics, Taxes and Business Strategy, Fifth Edition provides a framework for understanding how taxes affect decision-making, asset prices, equilibrium returns, and the financial and operational structure of firms. Teaching and Learning Experience This program presents a better teaching and learning experience-for you and your students: *Use a text from an active author team: All 5 authors actively teach the tax and business strategy course and provide students with relevant examples from both classroom and real-world consulting experience. *Teach students the practical uses for business strategy: Students learn important concepts that can be applied to their own lives. *Reinforce learning by using in-depth analysis: Analysis and explanatory material help students understand, think about, and retain information.
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264115609
Total Pages : 112 pages
Book Rating : 4.2/5 (641 download)
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.
Author : Donald A. Frederick
Publisher :
ISBN 13 :
Total Pages : 108 pages
Book Rating : 4.:/5 (89 download)
Download or read book Income Tax Treatment of Cooperatives: Handling of losses written by Donald A. Frederick and published by . This book was released on 1993 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Helen Miller
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (116 download)
Download or read book Intertemporal Income Shifting and the Taxation of Owner-managed Businesses written by Helen Miller and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Owner-managed businesses are a fast growing group; how they respond to tax is central to the challenge of how to tax labour relative to capital incomes. We use newly linked UK tax records to estimate how personal taxes affect the real economic activity and tax avoidance of company owner-managers. All of the large responses to personal taxes are attributable to intertemporal income shifting, and not to reductions in the total amount of income created. Taxable income is shifted across time to smooth income that fluctuates around tax kinks and to access preferential capital gains tax rates; these two forms of income shifting have different implications for welfare and policy. Accounting for income shifting reduces the estimated deadweight loss associated with a marginal increase in personal taxes by around 80%. Systematic retention of income within owner-managed companies is large, particularly for higher income individuals; this income is held as cash and equivalent assets, and is not associated with increased investment in business capital.
Author : Aspen Gorry
Publisher :
ISBN 13 :
Total Pages : 32 pages
Book Rating : 4.:/5 (13 download)
Download or read book The Elasticity of Taxable Income in the Presence of Intertemporal Income Shifting written by Aspen Gorry and published by . This book was released on 2018 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: Knowing the elasticity of taxable income (ETI) is crucial for understanding the effects of taxation on taxpayer behavior and consequently on tax revenues. Previous research finds that high-income individuals are the most sensitive to tax policy changes. However, these individuals have more opportunities to defer income to future tax bases by altering the composition of their compensation than lower-income individuals. This paper considers the taxable income elasticity when individuals can shift income across tax bases and thereby defer taxation. We decompose the elasticity of taxable income into a real response as well as an income shifting response. We measure the tax rate on deferred income by the expected tax gain from deferring income using stock options as developed by Hall and Liebman (2000). Our results demonstrate that income shifting is an important component of previous estimates of the ETI. Because shifted income is taxed at future dates, income shifting decreases the welfare loss from personal income taxation associated with previous estimates.
Author : Dominika Langenmayr
Publisher : International Monetary Fund
ISBN 13 :
Total Pages : 38 pages
Book Rating : 4.4/5 (2 download)
Download or read book Home Or Away? Profit Shifting with Territorial Taxation written by Dominika Langenmayr and published by International Monetary Fund. This book was released on 2022-09-09 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 2009, the United Kingdom abolished the taxation of profits earned abroad and introduced a territorial tax system. Under the territorial system, firms have strong incentives to shift profits abroad. Using a difference-in-differences research design, we show that the profitability of UK subsidiaries in low-tax countries increased after the reform compared to subsidiaries of non-UK multinationals in the same countries by an average of 2 percentage points. This increase in profit shifting also leads to increases in measured productivity of the foreign affiliates of UK multinationals of between 5 and 9 percent.
Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403517247
Total Pages : 484 pages
Book Rating : 4.4/5 (35 download)
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.
Author : Wolfgang Schön
Publisher : Springer Science & Business Media
ISBN 13 : 3540772766
Total Pages : 423 pages
Book Rating : 4.5/5 (47 download)
Download or read book Tax and Corporate Governance written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2008-03-12 with total page 423 pages. Available in PDF, EPUB and Kindle. Book excerpt: Academic research shows that well-known principal-agent and capital market problems are strongly influenced by tax considerations. Against this background, this volume is the first to present a fully-fledged overview of the interdependence of tax and corporate governance. Not only the basic political, legal and economic questions but also major topics like income measurement, shareholding structures, corporate social responsibility and tax shelter disclosure are covered.
Author : Sebastian Beer
Publisher : International Monetary Fund
ISBN 13 : 1513528327
Total Pages : 51 pages
Book Rating : 4.5/5 (135 download)
Download or read book Exploring Residual Profit Allocation written by Sebastian Beer and published by International Monetary Fund. This book was released on 2020-02-28 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schemes of residual profit allocation (RPA) tax multinationals by allocating their ‘routine’ profits to countries in which their activities take place and sharing their remaining ‘residual’ profit across countries on some formulaic basis. They have recently and rapidly come to prominence in policy discussions, yet almost nothing is known about their impact on revenue, investment and efficiency. This paper explores these issues, conceptually and empirically. It finds residual profits to be substantial, but concentrated in a relatively few MNEs, headquartered in few countries. The impact on tax revenue of reallocating excess profits under RPA, while adverse for investment hubs, appears beneficial for lower income countries even when the formula allocates by destination-based sales. The impact on investment incentives is ambiguous and specific both to countries and MNE groups; only if the rate of tax on routine profits is low does aggregate efficiency seem likely to increase.
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264202714
Total Pages : 44 pages
Book Rating : 4.2/5 (642 download)
Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.
Author : Kazuki Onji
Publisher : Austrialia-Japan Research Centre Crawford School of Economics & Government Anu College of Asia and P
ISBN 13 :
Total Pages : 40 pages
Book Rating : 4.3/5 ( download)
Download or read book Tax Law Asymmetries and Income Shifting written by Kazuki Onji and published by Austrialia-Japan Research Centre Crawford School of Economics & Government Anu College of Asia and P. This book was released on 2007 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Roger H. Gordon
Publisher :
ISBN 13 :
Total Pages : 88 pages
Book Rating : 4.3/5 (243 download)
Download or read book Are "real" Responses to Taxes Simply Income Shifting Between Corporate and Personal Tax Bases? written by Roger H. Gordon and published by . This book was released on 1998 with total page 88 pages. Available in PDF, EPUB and Kindle. Book excerpt: Two well-noted phenomena of recent decades are the increasing concentration of personal income and the declining rate of corporate profitability. This paper investigates to what extent these two trends have a common explanation extent these two trends have a common explanation-shifting of income to the personal tax base from the corporate tax base caused by the generally declining difference between personal tax rates and corporation income tax rates. This paper presents evidence that a substantial amount of income shifting has in fact occured since 1965, based on time-series regression analyses that reveal that an increase in corporate tax rates relative to personal rates resulted in an increase in reported personal income and a drop in reported corporate income, even after controlling for corproate use of debt finance and for the amount of corporate assets. We focus on one mechanism for shifting--changing the form of compensation for executives and other workers, such as between wage compensation and greater use of stock options. The potential importance of income shifting requires a reinterpretation of both the efficiency and distributional consequences of of changes in the tax structure.
Author : Jarkko Harju
Publisher :
ISBN 13 :
Total Pages : 40 pages
Book Rating : 4.:/5 (885 download)
Download or read book The Elasticity of Taxable Income and Income-Shifting: What is "Real" and What is Not? written by Jarkko Harju and published by . This book was released on 2014 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt:
