Income Shifting from Transfer Pricing

Income Shifting from Transfer Pricing
Author: Michael McDonald
Publisher: CreateSpace
Total Pages: 40
Release: 2015-01-01
Genre:
ISBN: 9781505389920

Download Income Shifting from Transfer Pricing Book in PDF, Epub and Kindle

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.

Addressing Base Erosion and Profit Shifting

Addressing Base Erosion and Profit Shifting
Author: OECD
Publisher: OECD Publishing
Total Pages: 91
Release: 2013-02-12
Genre:
ISBN: 9264192743

Download Addressing Base Erosion and Profit Shifting Book in PDF, Epub and Kindle

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.

Why is There Corporate Taxation in a Small Open Economy?

Why is There Corporate Taxation in a Small Open Economy?
Author: Roger H. Gordon
Publisher:
Total Pages: 22
Release: 1994
Genre: Corporations
ISBN:

Download Why is There Corporate Taxation in a Small Open Economy? Book in PDF, Epub and Kindle

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.

Fundamentals of International Transfer Pricing in Law and Economics

Fundamentals of International Transfer Pricing in Law and Economics
Author: Wolfgang Schön
Publisher: Springer Science & Business Media
Total Pages: 308
Release: 2012-02-15
Genre: Law
ISBN: 3642259804

Download Fundamentals of International Transfer Pricing in Law and Economics Book in PDF, Epub and Kindle

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.

OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Documentation and Country-by-Country Reporting

OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Documentation and Country-by-Country Reporting
Author: OECD
Publisher: OECD Publishing
Total Pages: 48
Release: 2014-09-16
Genre:
ISBN: 9264219234

Download OECD/G20 Base Erosion and Profit Shifting Project Guidance on Transfer Pricing Documentation and Country-by-Country Reporting Book in PDF, Epub and Kindle

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.

The Multilateral Convention on Mutual Administrative Assistance in Tax Matters Amended by the 2010 Protocol

The Multilateral Convention on Mutual Administrative Assistance in Tax Matters Amended by the 2010 Protocol
Author: OECD
Publisher: OECD Publishing
Total Pages: 112
Release: 2011-06-01
Genre:
ISBN: 9264115609

Download The Multilateral Convention on Mutual Administrative Assistance in Tax Matters Amended by the 2010 Protocol Book in PDF, Epub and Kindle

This publication contains the official text of the Multilateral Convention on Mutual Assistance in Tax Matters as amended by the 2010 Protocol.

Why is There Corporate Taxation in a Small Open Economy? The Role of Transfer Pricing and Income Shifting

Why is There Corporate Taxation in a Small Open Economy? The Role of Transfer Pricing and Income Shifting
Author: Roger H. Gordon
Publisher:
Total Pages: 35
Release: 2009
Genre:
ISBN:

Download Why is There Corporate Taxation in a Small Open Economy? The Role of Transfer Pricing and Income Shifting Book in PDF, Epub and Kindle

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.

Fundamentals of Transfer Pricing

Fundamentals of Transfer Pricing
Author: Michael Lang
Publisher: Kluwer Law International B.V.
Total Pages: 484
Release: 2021-06-18
Genre: Law
ISBN: 9403517247

Download Fundamentals of Transfer Pricing Book in PDF, Epub and Kindle

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.