Peter Vaz da Fonseca, Michele Nascimento Jucá, João Paulo da Torre Vieito
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引用次数: 0
摘要
本研究考察了新兴市场中的跨国公司,探讨了它们为建立避税地而采取的转让定价策略。这些公司采用各种机制(如转让定价、利润转移和无形资产的重新分配)来尽量减少税负。如今,无形资产水平的不断提高有助于更顺利地将利润转移到税负较低的司法管辖区。此外,这些公司将其生产活动转移到避税地,为公司逃税和避税创造了机会。尽管各国政府和国际组织努力建议不同国家采用最低税率,但这些公司仍能减少或完全避税。我们的研究样本包括 2010 年至 2020 年间总部位于新兴国家的公司。本研究引入了一些创新元素,如 "转让定价强度 "变量,该变量来自人工数据收集。这一变量有助于分析跨国公司采用的转让定价水平。此外,本研究的一个值得注意的贡献是使用了一种被称为 AREA 的非常规税收替代方法,它可以监测与短期和长期债务相关的税收优惠。研究结果表明,这些公司采用了多种手段(通常是组合使用)来减少其企业集团的税收。这些研究结果极大地促进了人们对企业税收优化做法错综复杂的理解,并为各国政府制定有力的政策、提高国际税收领域的透明度和问责制提供了宝贵的见解。
Tax havens and transfer pricing strategies: Insights from emerging economies
This study examines multinational companies in emerging markets, exploring their transfer pricing strategies for establishing tax havens. These companies employ various mechanisms (e.g., transfer pricing, profit transfers, and the reallocation of intangible assets) to minimize their tax liabilities. Today an increasing level of intangible assets facilitates smoother profit transfers to jurisdictions with lower tax burdens. Furthermore, these companies relocate their productive activities to tax havens, creating opportunities for corporate tax evasion and avoidance. Despite the efforts of governments and international organizations to propose the adoption of a minimum tax rate for different countries, these companies have been able to reduce or completely avoid paying taxes. Our study sample includes companies headquartered in emerging countries between 2010 and 2020. The study introduces some innovative elements, such as the variable “transfer pricing intensity,” which is derived from manual data collection. This variable enables analysis of the transfer pricing levels employed by multinational companies. In addition, a noteworthy contribution of this research is the use of an unconventional tax proxy known as AREA, which monitors the tax benefits associated with short- and long-term debts. The results demonstrate that these companies employ a diverse range of instruments, often in combination, to reduce taxes in their conglomerates. These findings contribute significantly to a deeper understanding of the intricacies surrounding corporate tax optimization practices and provide valuable insights for governments in formulating robust policies that promote transparency and accountability in the international tax landscape.
期刊介绍:
Thunderbird International Business Review is a peer-reviewed journal that is published six times a year in cooperation with the Thunderbird School of Global Business Management, the world"s leading institution in the education of global managers. The journal"s aim is to advance and disseminate research in the field of international business. Its main target audience includes academicians and executives in business and government who have an interest in international business.