Download or read book Transfer Pricing of Intrafirm Sales as a Profit Shifting Channel Evidence from German Firm Data written by Michael Overesch and published by . This book was released on 2012 with total page 29 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper investigates whether transfer pricing of intrafirm sales within multinationals represents an important channel of company tax planning. A simple theoretical model, considering profit shifting activities of a multinational company, is used to obtain empirical implications. The empirical analysis, based on a panel of German multinationals, considers directly the supposed tax response of intrafirm sales. The analysis shows a significantly negative impact of the local tax rate on the size of balance sheet items, which reflect intrafirm sales. Thus, the results suggest that transfer pricing of intrafirm sales constitutes an important channel of companies' profit shifting activities.
Download or read book Tax Transfer Pricing written by Andrea Musselli and published by Gruppo 24 Ore. This book was released on 2022-09-15T00:00:00+02:00 with total page 446 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.
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.
Download or read book OECD G20 Base Erosion and Profit Shifting Project Measuring and Monitoring BEPS Action 11 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 11.
Download or read book A missing link in the analysis of global value chains cross border flows of intangible assets taxation and related measurement implications written by World Intellectual Property Organization and published by WIPO. This book was released on 2017 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt: Understanding cross-border flows of disembodied knowledge, often associated with intellectual property (IP), is essential to analyzing how modern economies operate. This paper documents how available data to document these IP flows are distorted by various factors, including tax planning by multinational enterprises. It finds that tax-induced mismeasurement could be more than 35%, and greater for individual countries particularly high-tax-rate countries.
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.
Download or read book Advances in Financial Planning and Forecasting New Series Vol 6 written by Cheng F. Lee and published by Center for PBBEFR & Airiti Press. This book was released on 2015-01-01 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Advances in Financial Planning and Froecasting (New Series) is an annual publication designed to disseminate developments in the area of financial analysis, planning, and forecasting. The publication is a froum for statistical, quantitative, and accounting analyses of issues in financial analysis and planning in terms of finance, accounting, and economic data.
Download or read book International Trade in Services and Intangibles in the Era of Globalization written by Marshall B. Reinsdorf and published by University of Chicago Press. This book was released on 2009-08-01 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: Quantitative measures of international exchange have historically focused on trade in tangible products or capital. However, services have recently become a larger portion of developed economies and international trade, and will only increase in the future. In International Trade in Services and Intangibles in the Era of Globalization, Marshall Reinsdorf and Matthew J. Slaughter examine new and emerging patterns of trade, especially the growing importance of transactions involving services or intangible assets such as intellectual property. A distinguished team of contributors analyzes the challenges involved in measuring trade in intangibles, the comparative advantages enjoyed by United States service industries, and the heightened international competition for jobs, capital investment, economic growth, and tax revenue that results from trade in services. This comprehensive volume will be necessary reading for scholars seeking to understand the rapidly changing global economy.
Download or read book Global Logistics Management written by Wolfgang Kersten and published by Erich Schmidt Verlag GmbH & Co KG. This book was released on 2008 with total page 500 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book International Company Taxation written by Ulrich Schreiber and published by Springer Science & Business Media. This book was released on 2013-01-30 with total page 179 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.
Download or read book Estimating Illicit Financial Flows written by Alex Cobham and published by Oxford University Press. This book was released on 2020 with total page 224 pages. Available in PDF, EPUB and Kindle. Book excerpt: Illicit financial flows constitute a global phenomenon of massive but uncertain scale, which erodes government revenues and drives corruption in countries rich and poor. This book offers a critical examination of existing data and methodologies, identifying the most promising avenues for future improvement.
Download or read book International Tax Coordination written by Martin Zagler and published by Routledge. This book was released on 2010-06-30 with total page 331 pages. Available in PDF, EPUB and Kindle. Book excerpt: International taxation is a major research topic, and for a field of research at the intersection of so many disciplines there has been surprisingly little done across disciplinary boundaries. This book fills the gap by combining teams from business, economics, information science, law and political science to offer a unique and innovative approach to the issue of international tax coordination. All the chapters are written in collaboration between at least two authors from two different disciplines. This approach offers a rich and nuanced understanding of the many issues of international tax coordination. The book collects seven papers, each one a valuable contribution in itself, beginning with current problems of international taxation and finishing with potential solutions. The essays explore current EU legislation, tax avoidance and tax fraud, as well as double tax agreements, dividend repatriation and hybrid finance and tax planning. Providing methodological answers to the question of how to conduct interdisciplinary research, the book also gives an accessible introduction into research questions and answers that are important in related disciplines for scholars in various areas. This book will be of interest to postgraduates and researchers in the fields of economics, business, informational science, law and political science, as well as to professional accountants and tax lawyers.
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.
Download or read book Trade Policy Research written by and published by . This book was released on 2011 with total page 396 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Intra firm Trade written by Organisation for Economic Co-operation and Development and published by . This book was released on 1993 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Dealing Effectively with the Challenges of Transfer Pricing written by OECD and published by OECD Publishing. This book was released on 2012-01-18 with total page 110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report addresses the practical administration of transfer pricing programmes by tax administrations.
Download or read book Corporate Profit Shifting written by Dorian L. Peters and published by . This book was released on 2015 with total page 171 pages. Available in PDF, EPUB and Kindle. Book excerpt: Congress and the Obama Administration have expressed interest in addressing multinational corporations' ability to shift profits into low- and no-tax countries with little corresponding change in business operations. Several factors appear to be driving this interest. Economists have estimated that profit shifting results in significant tax revenue losses annually, implying that reducing the practice could help address deficit and debt concerns. Profit shifting and base erosion are also believed to distort the allocation of capital as investment decisions are overly influenced by taxes. Fairness concerns have also been raised. If multinational corporations can avoid or reduce their taxes, other taxpayers (including domestically focused businesses and individuals) may perceive the tax system as unfair. At the same time, policymakers are also concerned that American corporations could be unintentionally harmed if careful consideration is not given to the proper way to reduce profit shifting. This book is intended to assist Congress as it considers what, if any, action to curb profit shifting. This book discusses the methods used for shifting profits only to the extent that it is necessary for interpreting the data or discussing policy options. In addition, this book addresses tax havens; basic concepts and policy issues of U.S. international corporate taxation; and reforms of U.S. international taxation.
