Why Is There Corporate Taxation In A Small Open Economy The Role Of Transfer Pricing And Income Shifting PDF Download
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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 | : 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 | : Elizabeth A. King |
Publisher | : Springer Science & Business Media |
Total Pages | : 294 |
Release | : 1994 |
Genre | : Business & Economics |
ISBN | : 0792393929 |
Download Transfer Pricing and Valuation in Corporate Taxation Book in PDF, ePub and Kindle
This book analyzes the disparities both between federal statutes and regulations, and regulations and administrative practices, in two highly controversial areas of corporate tax policy: intra-company transfer pricing and intangible asset valuations. It addresses issues that can mean hundreds of millions of dollars to individual corporations, and a significant fraction of the federal government's revenue base. Tax practitioners and consultants who are understandably frustrated in their efforts to divine the IRS's reasoning in transfer pricing and valuation issues will find the book very useful. It will also find an audience among elected representatives, other public officials, and tax lobbyists in the process of evaluating existing corporate tax policy or formulating alternative tax policies. In addition, the book is a useful reference for academics studying international taxation, public finance, and treaty compliance.
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 | : 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
Author | : M.K. McKeehan |
Publisher | : |
Total Pages | : |
Release | : 2017 |
Genre | : |
ISBN | : |
Download Balancing Act : Weighing the Factors Affecting the Taxation of Capital Income in a Small Open Economy Book in PDF, ePub and Kindle
Alternative economic theories yield dramatically different prescriptions for optimal capital taxation in small open economies. On the one hand, foreign firms, including those with investments that yield firm-specific above-normal returns, have a large number of alternative investment opportunities; this suggests that the supply of foreign direct investment is highly elastic, which implies that small open economies should avoid imposing any source-based taxes on capital income. On the other hand, governments invariably want to tax any above-normal returns earned by location-specific capital, especially if the returns accrue to foreigners, and to take full advantage of the potential revenue increase from any "treasury transfer" effect that arises due to residence-based tax systems with foreign tax credits, such as that utilized by the USA. These factors suggest that investment is highly inelastic with respect to capital taxation, so that source-based capital income taxation is desirable; indeed, in one special case, the capital income tax rate for a small open economy should equal the relatively high US tax rate. Moreover, this difficult trade-off is in practice complicated by numerous additional factors: deferral of unrepatriated profits and cross-crediting of foreign tax credits for the US multinationals, foreign direct investment from firms from countries that, unlike the USA, operate territorial systems, and the existence of opportunities for both international capital income shifting and labour income shifting. In this paper, the authors analyze optimal capital income taxation in a small open economy model that attempts to balance these conflicting factors.