FEN: Differences in Taxation & Corporate Finance (Topic)最新文献_第3页

Implications of Flexibility in Income Shifting under Losses 损失下收入转移灵活性的含义

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2019-02-10 DOI: 10.2139/ssrn.3327666

Arnt O. Hopland, Petro Lisowsky, M. Mardan, Dirk Schindler

引用次数: 6

How The Netherlands Became a Tax Haven for Multinationals 荷兰如何成为跨国公司的避税天堂

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2019-01-17 DOI: 10.2139/SSRN.3317629

J. Vleggeert, H. Vording

{"title":"How The Netherlands Became a Tax Haven for Multinationals","authors":"J. Vleggeert, H. Vording","doi":"10.2139/SSRN.3317629","DOIUrl":"https://doi.org/10.2139/SSRN.3317629","url":null,"abstract":"The Netherlands tax environment for multinational foreign directive investment (FDI) has been characterized as ‘a tax haven’ or, perhaps more accurately, as a ‘conduit financial centre’. Anyway, with a share of 25% in the worldwide market for tax-driven FDI diversion, the Dutch tax planning industry has become a prominent target of recent OECD and EU anti-avoidance measures. Adaptations in many of the relevant Dutch tax rules are by now under way. \u0000 \u0000The paper aims at the interactions between (a) the making of the relevant tax environment and (b) the rise of a specialized industry for FDI tax planning over the last century. The basic mechanism will be shown to be simple. A century ago, Dutch rules for taxation of cross-border FDI started to develop from a consistent view: FDI should not be hindered by tax borders. This served the interests of a small open economy hosting many internationally successful enterprises. A specialized tax planning industry only emerged in the second half of the 20th century as a by-product of international tax policies aimed at substantial business interests. But as this industry grew, its role in shaping and re-shaping the relevant rules increased. Only very recently, this role has begun to decline due to both international policy pressure and national public opinion. \u0000 \u0000Issues to be discussed from this perspective include the development of Dutch tax treaty policy, the Dutch position in international tax coordination processes, and the development of relevant rules in Dutch tax law, starting with the first Dutch income tax law (1893/4) and with a focus on post-1945 developments.","PeriodicalId":385233,"journal":{"name":"FEN: Differences in Taxation & Corporate Finance (Topic)","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2019-01-17","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"116648020","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 3

The Good Place or the Bad Place? The Ted Danson of International Tax: The OECD and its Claim to Fame, BEPS. 好地方还是坏地方?《国际税收的泰德·丹森:经合组织及其成名之路》，BEPS。

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2018-12-18 DOI: 10.2139/SSRN.3303014

Paul de Haan, G. Heij

引用次数: 0

International Tax, Regulatory Arbitrage and the Growth of Transnational Corporations 国际税收、监管套利与跨国公司的成长

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2018-11-20 DOI: 10.18356/7B01478A-EN

S. Picciotto

{"title":"International Tax, Regulatory Arbitrage and the Growth of Transnational Corporations","authors":"S. Picciotto","doi":"10.18356/7B01478A-EN","DOIUrl":"https://doi.org/10.18356/7B01478A-EN","url":null,"abstract":"This paper traces the history of international corporate taxation, discusses how transnational corporations (TNCs), through their tax advisers, have helped to shape the system, and suggests that this is important in understanding the development of TNCs. It argues that a key competitive advantage of TNCs is their ability to exploit differences in corporate tax rules, as a form of regulatory arbitrage, which is facilitated by the inadequate coordination of those rules. It focuses on the divergence between the understanding in business, economics and international studies that TNCs are unitary firms and the principle which has increasingly hardened in international tax rules, especially on transfer pricing, that the various affiliates of TNCs in different countries should be treated as if they were independent entities dealing with each other at armâ€™s length. It argues that this facilitates tax avoidance, which is one of the strategies of the exploitation of regulatory differences, or regulatory arbitrage, which has contributed to the growth and oligopolistic dominance of large TNCs. While claiming that they merely obey the laws of each country where they do business, TNCs have taken advantage of their global reach to mould laws and normative practices, and develop structures taking maximum advantage of the loose coordination of global governance regimes.","PeriodicalId":385233,"journal":{"name":"FEN: Differences in Taxation & Corporate Finance (Topic)","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2018-11-20","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131843248","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 12

Is Panama Really Your Tax Haven? Secrecy Jurisdictions and the Countries They Harm 巴拿马真的是你的避税天堂吗?保密司法管辖区及其损害的国家

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2018-10-16 DOI: 10.2139/ssrn.3267366

P. Janský, M. Meinzer, Miroslav Palanský

{"title":"Is Panama Really Your Tax Haven? Secrecy Jurisdictions and the Countries They Harm","authors":"P. Janský, M. Meinzer, Miroslav Palanský","doi":"10.2139/ssrn.3267366","DOIUrl":"https://doi.org/10.2139/ssrn.3267366","url":null,"abstract":"Secrecy jurisdictions provide services that enable the residents of other countries to escape the laws and regulations of their home economies, evade tax, or hide their legally or illegally obtained assets. Recent offshore leaks offer only a limited and biased view of the world of financial secrecy. In this paper we quantify which secrecy jurisdictions provide secrecy to which countries and assess how successful countries are in targeting these jurisdictions with their policies. To that objective we develop the Bilateral Financial Secrecy Index (BFSI) and estimate it for 86 countries by quantifying the financial secrecy supplied to them by up to 100 secrecy jurisdictions. We then evaluate two major recent policy efforts by comparing them with the results of the BFSI. First, we focus on the blacklisting process of the European Commission and find that most of the important secrecy jurisdictions for EU member states have been identified by the lists. Second, we link the results to data on active bilateral automatic information exchange treaties to assess how well-aimed are the policymakers’ limited resources. We argue that while low-secrecy jurisdictions’ gains are maximized if a large share of received secrecy is covered by automatic information exchange, tax havens aim not to activate these relationships with countries to which they supply secrecy. Our results show that so far, some major secrecy jurisdictions successfully keep their most prominent relationships uncovered by automatic information exchange, and activating these relationships may thus be an effective tool to curb secrecy.","PeriodicalId":385233,"journal":{"name":"FEN: Differences in Taxation & Corporate Finance (Topic)","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2018-10-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"121794587","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 17

Who Bears the Corporate Tax Incidence? Empirical Evidence from India 谁承担公司税的发生?来自印度的经验证据

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2018-03-14 DOI: 10.2139/ssrn.3159706

Samiksha Agarwal, L. Chakraborty

引用次数: 0

Implicit Corporate Taxes and Income Shifting 隐性公司税和收入转移

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2018-03-07 DOI: 10.2139/ssrn.2993950

Kevin S. Markle, Lillian F. Mills, Braden M. Williams

引用次数: 37

Will BEPS Allow New Zealand to Finally Tax Google? BEPS会让新西兰最终对谷歌征税吗?

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2017-12-24 DOI: 10.2139/ssrn.3092781

Andrew M. C. Smith

{"title":"Will BEPS Allow New Zealand to Finally Tax Google?","authors":"Andrew M. C. Smith","doi":"10.2139/ssrn.3092781","DOIUrl":"https://doi.org/10.2139/ssrn.3092781","url":null,"abstract":"Tax avoidance by major US multinationals has been extremely topical over the last decade since the GFC. One of the MNEs at the forefront of this controversy is Google. It has been able to snare a dominant share of the international online advertising market without paying any significant amounts of tax in countries where it obtains orders other than the US. It has been able to do so by structuring its affairs so that it does not have a “permanent establishment” (PE) in New Zealand. Instead its New Zealand customers conclude contracts directly with Google subsidiaries in countries which New Zealand has concluded a DTA with but otherwise impose low taxes such as Singapore and Ireland. The BEPS project has been undertaken by the OECD to deal with MNE tax avoidance. New Zealand has been an active participant in this project seeing a multilateral forum such as the OECD as the best way to deal with this problem rather than taking independent steps of its own. The multilateral instrument (MLI) arising out of the BEPS project is designed to modify a large number of the world’s DTAs at one time to deal with this tax avoidance problem such PE avoidance by MNEs such as Google. The MLI is a modular convention in that signatory states do not have to agree to adopt all parts of it. This paper analyses the responses of several of New Zealand’s key DTA partners in respect of Part IV of the MLI dealing with PE avoidance. It will be concluded that the MLI is unlikely to prove effective for New Zealand in deal with tax avoidance by Google. It appears that New Zealand may need to adopt a unilateral strategy to effectively tax Google on its profits earned from New Zealand advertisers outside the BEPS project which is proposed in a bill introduced to the New Zealand Parliament in December 2017. Consideration is finally made whether this bill will be effective in securing tax revenue from MNEs such as Google.","PeriodicalId":385233,"journal":{"name":"FEN: Differences in Taxation & Corporate Finance (Topic)","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2017-12-24","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"121728923","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

Why Do Some Companies Leave? Evidence on the Factors that Drive Inversions 为什么有些公司会离开?关于驱动反转因素的证据

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2017-12-06 DOI: 10.2139/ssrn.3083715

Douglas O. Cook, Joseph Stover

引用次数: 0

The Sales Country as a Tax Credit Country – Implementation Issues, Complexity Costs and Tax Planning 销售国作为税收抵免国家-实施问题，复杂性成本和税收规划

FEN: Differences in Taxation & Corporate Finance (Topic) Pub Date : 2017-11-24 DOI: 10.2139/ssrn.3076774

Lisa Maria Fell

{"title":"The Sales Country as a Tax Credit Country – Implementation Issues, Complexity Costs and Tax Planning","authors":"Lisa Maria Fell","doi":"10.2139/ssrn.3076774","DOIUrl":"https://doi.org/10.2139/ssrn.3076774","url":null,"abstract":"The international taxation of multinational enterprises (MNEs) stands under public and political pressure. The OECD BEPS project is striving for taxation in line with economic activity and value creation. While this might prevent book profit shifting it comes at the risk of investment shifting and corresponding losses in tax revenue. Academics put forward destination-based taxation to prevent investment shifting. This might come at the cost of taxing MNEs’ profits not in all places of value creation. This conflict can be solved by a mechanism first proposed by Schreiber/Fell. Possible further implementation forms, especially within the OECD framework of transfer pricing and possible instruments to use shall be examined within this paper. The implementation forms shall be compared based on the involvements of information, coordination, differentiation, cooperation and consensus need, while taking into account the remaining flexibility for states involved and tax planning opportunities. While all three possible implementation forms within transfer pricing could be feasible next steps, taking into account preferences of states involved, the mechanism as such can be questioned from a stability point of view. While all states involved despite tax havens could be possible winners when entering the mechanism, sales countries could not be incentivized to uphold it from a pure revenue perspective. As a consequence, states involved should take the long-term trends in taxation into account in order to think about a solution based on coordination.","PeriodicalId":385233,"journal":{"name":"FEN: Differences in Taxation & Corporate Finance (Topic)","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2017-11-24","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"122486731","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 1