Research on the multinational group transfer pricing based on minimization of tax burden

2009 ◽  
Author(s):  
Xiu-hua Li ◽  
Guang-liang Wang
Keyword(s):  
Transfer Pricing ◽  
Tax Burden ◽  
Multinational Group ◽  
Group Transfer

scholarly journals The Use of International Tax Planning in Subsidiaries from the Financial and ICT Sectors in the Czech Republic

2021 ◽  
Vol 24 (1) ◽  
pp. 182-196
Author(s):  
Vít Jedlička
Keyword(s):  
Global Economy ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Tax Planning ◽  
Tax Burden ◽  
Effective Tax Rate ◽  
Tax Havens ◽  
Tax Rate ◽  
Dummy Variable ◽  
International Tax

Tax avoidance is an important element of management in the global economy. Managers use tax havens for reducing a company’s effective tax rate. The most common practices in international tax planning can be divided into three groups: loans and their related interest, royalties, and transfer pricing. The aim of this article is to find the determinants of the tax burden faced by foreign-owned subsidiaries. Therefore, a model was created for the tax burden, focusing on the special position of subsidiaries within international tax planning. For this purpose, taxes/outcomes was established as a new dependent variable. The panel data used include Czech companies that are owned by parent companies located in other EU countries. The model distinguishes EU tax havens from regular member states; sector dummy variables are also included. The regression model that was created did not confirm the assumed dependencies. Rather, it indicated other important determinants: profitability, the share of intangible assets, size, and the dummy variable for the ICT sector. Based on the regression results, the independent variables connected with known tax planning schemes have relatively low importance. The significance of these results can be seen in the subsequent conclusions. First of all, there is no difference between the subsidiaries’ tax burdens based on the parent company’s location. Corporations use international tax planning whether or not they are owned from a tax haven. The second significant conclusion indicates the importance of certain sectors and their attributes concerning the tax burden. Companies from the ICT sector are linked to a lower tax burden. On the other hand, the dependencies within the financial sector are not statistically significant. From the perspective of further research, it would be constructive to incorporate the subsidiary’s position within the group.

scholarly journals Analisis Keputusan Transfer Pricing Berdasarkan Pajak, Tunneling dan Exchange Rate

2020 ◽  
Vol 20 (2) ◽  
Author(s):  
Hani Sri Mulyani ◽  
Endah Prihartini ◽  
Dadang Sudirno
Keyword(s):  
Exchange Rate ◽  
Exchange Rates ◽  
Stock Exchange ◽  
Transfer Pricing ◽  
Tax Burden ◽  
Manufacturing Companies ◽  
Pricing Decisions ◽  
Pricing Decision ◽  
The Government ◽  
Positive Effect

Tax has two points of view, for the government tax is a source of state revenue that has the largest contribution, but for tax companies is a burden that must be paid. Often companies do tax planning strategies so that the tax burden that must be borne by the company becomes smaller. Companies usually exploit loopholes from the use of accounting methods allowed by accounting and taxation rules. Transfer Pricing is one of the ways companies take to reduce the tax burden. This study aims to determine and obtain empirical evidence about the effect of tax, tunneling and exchange rates on transfer pricing decisions both partially and simultaneously on manufacturing companies listed on the Indonesia Stock Exchange (IDX) for the 2013-2017 period. The research method used is descriptive and verification analysis method. The population in this study were 144 manufacturing companies listed on the Indonesia Stock Exchange in the period 2013-2017. Sampling using a purposive sampling method and obtained a sample of 20 companies. The results of this study indicate that partially significant positive effect on transfer pricing decisions, tunneling does not significantly influence the transfer pricing and exchange rate decisions do not significantly influence the transfer pricing decision, but simultaneously the results of this study indicate that taxes, tunneling and exchange rates affect significant to the transfer pricing decision.

Tax Avoidance and Transfer Pricing

2021 ◽  
Vol 8 (2) ◽  
pp. 28-39
Author(s):  
Nikolaos Eriotis ◽  
Spyros Missiakoulis ◽  
Ioannis Dokas ◽  
Marios Tzavaras ◽  
Dimitrios Vasiliou
Keyword(s):  
Causal Relationship ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Multinational Companies ◽  
Tax Burden ◽  
Tax Havens ◽  
The Past ◽  
Extensive Analysis ◽  
Using Data ◽  
International Character

Globalization has led multinational companies, beyond intensifying their competitiveness, to seek ways to maximize profits through tax avoidance. The international character enables them to transfer profits to tax havens or seek transactions that will enable them to avoid, postpone, or pay lower taxes. Although the previous allegations have been hypothesized by researchers, tax audits, and governments, it is difficult to prove due to the chaotic data and the causal relationship between variables. The present study compared the tax burden of 971 multinationals and 1,160 independent companies for the years 2010-2017 in Greece, using data from the Amadeus Tp-Catalyst database and confirmed previous research on significant differences in terms of profits and tax burdens. To the authors' knowledge, there has not been attempted such an extensive analysis for Greece in the past.

scholarly journals Assessment of Ukraine’s readiness for international automatic exchange of information for tax purposes

2021 ◽  
Vol 2021 (2) ◽  
pp. 85-97
Author(s):  
Yana OLIYNYK ◽  
◽  
Maria KUCHERIAVA ◽  
Keyword(s):  
Organizational Support ◽  
Transfer Pricing ◽  
Action Plan ◽  
Competent Authority ◽  
International Exchange ◽  
General Distribution ◽  
Multinational Group ◽  
Exchange Of Information ◽  
Constituent Element ◽  
State Tax

The implementation of a constituent element of a three-tier model of transfer pricing documentation – a report in the context of the countries of the multinational group of companies – is a prerequisite for Ukraine's joining the Multilateral Competent Authority Agreement as a measure for implementation of Action 13. The Ministry of Finance of Ukraine, together with the State Tax Service of Ukraine, developed a Roadmap on preparation and harmonization of the draft regulatory legal acts necessary to ensure implementation of the Law of Ukraine dated January 16, 2020 No. 466-IX, according to which the development, approval and registration of the regulatory legal acts for the country-by-country reporting and the procedure for filling it out must be completed until November 23, 2020. The purpose of the article is to determine the institutional basis for improving the legislation of Ukraine in the field of international exchange of information for tax purposes, in particular, the development of recommendations and proposals of the OECD in the field of country-by-country reporting of the multinational group of companies. In the course of study, the authors examined the OECD documents that form the institutional basis for the development of methodological and organizational support for reporting in the context of countries. In accordance with Action 13 of the BEPS Action Plan, jurisdictions of the world have undertaken to increase the transparency of taxation by enshrining in law the requirement to disclose information on the general distribution of their income, taxes and other indicators by the location of economic activity of multinational group of companies. The comparative analysis of the termino­logy and content of information to be disclosed in the country-by-country reporting in accordance with OECD documentation and Law № 466-IX shows that there is a discrepancy in terminology, indicators and degree of data disclosure in some indicators.

Levels taxation countries the EU and Ukraine’s

2019 ◽  
pp. 131-160
Author(s):  
Helena Borzenko ◽  
Tamara Panfilova ◽  
Mikhail Litvin
Keyword(s):  
European Union ◽  
Uniform Distribution ◽  
Tax Burden ◽  
Tax System ◽  
Tax Legislation ◽  
Improvement Process ◽  
Tax Systems ◽  
Historical Comparative ◽  
Different Levels ◽  
The Eu

Purpose articles rassm and experience and benefits systems taxation countries European Union, manifestation iti the main limitations domestic taxlegislation and wired STI their comparisons. In general iti ways the provisiontax reporting countries Eurozone in the appropriate organs, dove STI need theintroduction Ukraine electronic methods receiving and processing such reports.define iti key directions reforming domestic tax legislation. Methodology research is to use aggregate methods: dialectical, statistical, historical, comparative. Scientific novelty is to are provided recommendations for improvement ofefficiency systems taxation of our states in international ratings characterizingtax institutions country. Therefore, despite some problems in legislation heldcomparative study systems taxation EU and Ukraine. Conclucions Coming fromof this, the main directions reforming tax systems Ukraine, in our opinion,today should become: improvement process administration, reduce scales evasiontaxes, provision more uniform distribution tax burden between taxpayers, themaximum cooperation tax bodies different levels as well adjustment systemselectronic interactions tax authorities and payers, tax system must contain ascan less unfounded benefits, consistent with the general by politics pricing.

TRANSFER FİYATLAMA UYGULAMASININ İŞLETME PERFORMANSINA ETKİSİ VE VERGİSEL AÇIDAN DEĞERLENDİRİLMESİ

2014 ◽  
Vol 1 (2) ◽  
pp. 187
Author(s):  
Serdar KUZU
Keyword(s):  
Business Performance ◽  
Transfer Pricing ◽  
Tax Law ◽  
Economic Activities ◽  
Tax System ◽  
Goods And Services ◽  
Tax Legislation ◽  
International Transactions ◽  
The Cost ◽  
The Impact

The size of international trade continues to extend rapidly from day to day as a result of the globalization process. This situation causes an increase in the economic activities of businesses in the trading area. One of the main objectives of the cost system applied in businesses is to be able to monitor the competitors and the changes that can be occured as a result of the developments in the sector. Thus, making cost accounting that is proper according to IAS / IFRS and tax legislation has become one of the strategic targets of the companies in most countries. In this respect, businesses should form their cost and pricing systems according to new regulations. Transfer pricing practice is usefull in setting the most proper price for goods that are subject to the transaction, in evaluating the performance of the responsibility centers of business, and in determining if the inter-departmental pricing system is consistent with targets of the business. The taxing powers of different countries and also the taxing powers of different institutions in a country did not overlap. Because of this reason, bringing new regulations to the tax system has become essential. The transfer pricing practice that has been incorporated into the Turkish Tax System is one of the these regulations. The transfer pricing practice which includes national and international transactions has been included in the Corporate Tax Law and Income Tax Law. The aim of this study is to analyse the impact of goods and services transfer that will occur between departments of businesses on the responsibility center and business performance, and also the impact of transfer pricing practice on the business performance on the basis of tax-related matters. As a result of the study, it can be said that transfer pricing practice has an impact on business performance in terms of both price and tax-related matters.

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