Why Is There Corporate Taxation In A Small Open Economy The Role Of Transfer Pricing And Income Shifting
Download Why Is There Corporate Taxation In A Small Open Economy The Role Of Transfer Pricing And Income Shifting full books in PDF, epub, and Kindle. Read online free Why Is There Corporate Taxation In A Small Open Economy The Role Of Transfer Pricing And Income Shifting ebook anywhere anytime directly on your device. Fast Download speed and no annoying ads. We cannot guarantee that every ebooks is available!
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.
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.
Author | : Roger Hall Gordon |
Publisher | : |
Total Pages | : |
Release | : 1994 |
Genre | : |
ISBN | : |
Download Why is There Corporation Taxation in a Small Open Economy? Book in PDF, Epub and Kindle
Author | : Elizabeth King |
Publisher | : Springer Science & Business Media |
Total Pages | : 199 |
Release | : 2008-10-11 |
Genre | : Business & Economics |
ISBN | : 0387781838 |
Download Transfer Pricing and Corporate Taxation Book in PDF, Epub and Kindle
National tax authorities individually determine multinational ?rms’ country-speci?c tax liabilities by applying one or more sanctioned transfer pricing methodologies. These methodologies are founded on basic assumptions about market structure and ?rm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ?nancial and commodities markets. For these reasons, multinational ?rms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation. Uncertainties in corporate tax liability are extremely costly, both for individual corporations and from an economy-wide perspective. Firms pay exorbitant fees to have tax attorneys, accountants and economists prepare the documentation required by tax authorities to substantiate their intercompany pricing practices and defend their tax positions on audit. Corporate tax liabilities are also potentially much higher than they would be under a more transparent and predictable transfer pricing regime (due to the potential for double taxation and penalties), and investors’ returns are reduced accordingly. The FASB’s Interpretation No. 48, Accounting for Uncertainty in Income Taxes (released on July 13, 2006), has motivated multinational ?rms to increase their reserves substantially (in many cases at the insistence of their au- tors), reducing the total funds available for productive investment. 1 The current transfer pricing regimes are embodied in the OECD Guidelines, individual OECD member countries’ interpretations thereof, the U. S.
Author | : Martin Feldstein |
Publisher | : University of Chicago Press |
Total Pages | : 338 |
Release | : 2007-12-01 |
Genre | : Business & Economics |
ISBN | : 0226241874 |
Download The Effects of Taxation on Multinational Corporations Book in PDF, Epub and Kindle
The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.
Author | : Elizabeth King |
Publisher | : Springer Science & Business Media |
Total Pages | : 294 |
Release | : 2007-05-08 |
Genre | : Law |
ISBN | : 0306482185 |
Download Transfer Pricing and Valuation in Corporate Taxation Book in PDF, Epub and Kindle
Transfer Pricing and Valuation in Corporate Taxation analyzes the disparities between both federal statutes and regulations, and r- ulations and administrative practice, in a highly controversial area of corporate tax policy: intra-company transfer pricing for tax p- poses. It addresses issues that often mean millions of dollars to in- vidual corporations, and a significant fraction of the federal gove- ment’s revenue base. These disparities between law, regulations, and administrative practice are concerning on a number of grounds. First, they - pose considerable economic costs by inducing corporations to engage in a variety of “rent-seeking” activities designed to reduce their - pected tax liabilities, and by requiring the IRS to devote still more to enforcement efforts that are very often futile. Second, they are in- ; herently undemocratic. Administrative practice is currently ad hoc by relying on dispute resolution procedures that can and do yield very different settlements on disputed tax issues from one case to another, the IRS often ends up treating similarly situated cor- rations very differently. Moreover, to the extent that the disp- ity between statute and implementation reflects the IRS’s failure to carry out Congress’ will, the laws passed by duly elected officials are effectively being superseded by administrative procedure, developed incrementally by individuals who are not answerable to an electorate.
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.
Author | : Sebastian Beer |
Publisher | : International Monetary Fund |
Total Pages | : 45 |
Release | : 2018-07-23 |
Genre | : Business & Economics |
ISBN | : 1484370538 |
Download International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots Book in PDF, Epub and Kindle
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.
Author | : Eric J. Bartelsman |
Publisher | : |
Total Pages | : 36 |
Release | : 2000 |
Genre | : Corporations |
ISBN | : |
Download Why Pay More? Book in PDF, Epub and Kindle
Author | : Jennifer Blouin |
Publisher | : Now Pub |
Total Pages | : 78 |
Release | : 2012 |
Genre | : Business & Economics |
ISBN | : 9781601985323 |
Download Taxation of Multinational Corporations Book in PDF, Epub and Kindle
Taxation of Multinational Corporations aggregates the large body of international tax literature succinctly in one location