“The client can get caught out”: Tax structure maintainability and the intricacies of tax planning aggressiveness

IF 3.2 3区 管理学 Q1 BUSINESS, FINANCE
Maryse Mayer, Yves Gendron
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Abstract

In this field study, we examine tax advisors' decision‐making process when developing tax planning arrangements. Through interviews with 40 tax advisors, our analysis indicates that tax savings may come at a price in practice by unveiling adverse post‐implementation experiences shared by tax partners. Partners find themselves in a tricky position at the time they form their recommendation as they cannot be certain that their client will be able to “live with their tax structure”—that is, maintain it and cope with the inherent risks once implemented. Their main concern is that their client may “get caught out” by a structure too aggressive or complicated for them, having no control over the client's behavior once the plan is implemented. This has significant implications in the tax planning decision‐making process as these concerns shape how partners adapt their work to their client's perceived competency and possibly restrain corporate firms' tax aggressiveness. Following Feller and Schanz (2017, Contemporary Accounting Research, 34(1), 494–524), we conceive of this as the fourth hurdle of tax planning— whether a tax structure is maintainable, as perceived by tax advisors—and unpack how it operates. Interestingly, restraining the client's tax planning aggressiveness (and the corresponding potential tax savings) is not necessarily perceived by partners as detrimental to the client relationship. Our findings contribute to a better understanding of tax planning in action, highlighting how tax partners seek to influence their client's tax planning aggressiveness.
"客户可能会被套牢":税务结构的可维护性和税务筹划的复杂性
在这项实地研究中,我们考察了税务顾问在制定税收筹划安排时的决策过程。通过对 40 位税务顾问的访谈,我们的分析表明,在实践中,税务合伙人所分享的不利的实施后经验表明,节税可能是要付出代价的。合伙人在提出建议时会发现自己处于一个棘手的境地,因为他们无法确定客户是否能够 "与他们的税务结构共存"--也就是说,一旦实施,他们是否能够维持并应对固有的风险。他们主要担心的是,客户可能会被过于激进或复杂的结构 "套牢",而一旦计划实施,他们又无法控制客户的行为。这对税务筹划决策过程有重大影响,因为这些顾虑决定了合伙人如何根据客户的认知能力来调整他们的工作,并有可能限制企业公司的税务侵略性。效仿 Feller 和 Schanz(2017,Contemporary Accounting Research,34(1),494-524),我们将其视为税务筹划的第四个障碍--税务顾问眼中的税务结构是否可维持--并解读其如何运作。有趣的是,合伙人并不一定认为限制客户税收筹划的积极性(以及相应的潜在节税)会损害客户关系。我们的研究结果有助于更好地理解税务筹划的实际操作,突出了税务合伙人如何设法影响客户的税务筹划积极性。
本文章由计算机程序翻译,如有差异,请以英文原文为准。
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来源期刊
CiteScore
6.20
自引率
11.10%
发文量
97
期刊介绍: Contemporary Accounting Research (CAR) is the premiere research journal of the Canadian Academic Accounting Association, which publishes leading- edge research that contributes to our understanding of all aspects of accounting"s role within organizations, markets or society. Canadian based, increasingly global in scope, CAR seeks to reflect the geographical and intellectual diversity in accounting research. To accomplish this, CAR will continue to publish in its traditional areas of excellence, while seeking to more fully represent other research streams in its pages, so as to continue and expand its tradition of excellence.
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