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

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.

2018 ◽  
Vol 6 (2) ◽  
pp. 105
Author(s):  
Paskalis A Panjalusman ◽  
Erik Nugraha ◽  
Audita Setiawan

AbstractThis study aims to examine the effect of transfer pricing on tax avoidance. The independent variable used in this study is transfer pricing. While the dependent variable used in this study is tax avoidance, which is measured using the effective tax rate (GAAP-ETR). The population in this study amounted to 15 multinational manufacturing sector companies listed on the Indonesia Stock Exchange (IDX) during the 2014-2017 period. Determination of research samples using purposive sampling method and obtained a sample of 9 multinational manufacturing companies based on certain criteria. The results of the study show that transfer pricing has an effect but not significantly on tax avoidance. Key Word. transfer pricing; tax avodiance AbstrakPenelitian ini bertujuan untuk menguji pengaruh transfer pricing terhadap penghindaran pajak (tax avoidance). Variabel independen yang digunakan dalam penelitian ini adalah transfer pricing. Sedangkan variabel dependen yang digunakan dalam penelitian ini adalah penghindaran pajak (tax avoidance) yang diukur menggunakan effective tax rate (GAAP-ETR). Populasi dalam penelitian ini berjumlah 15 perusahaan sektor manufaktur multinasional yang terdaftar di Bursa Efek Indonesia (BEI) selama periode 2014-2017. Penentuan sampel penelitian menggunakan metode purposive sampling dan memperoleh sampel sebanyak 9 perusahaan manufaktur multinasional berdasarkan kriteria tertentu. Hasil penelitian menunjukan bahwa transfer pricing berpengaruh tetapi tidak signifikan terhadap penghindaran pajak (tax avoidance). Kata Kunci. transfer pricing; penghindaran pajak


2021 ◽  
Vol 0 (0) ◽  
Author(s):  
Thomas Kollruss

Abstract Legal frameworks have an enormous influence on the concrete choice of legal form, especially in (multinational) groups of companies. For example, tax regulations and accounting standards directly influence the legal enterprise’s structure, including the shareholding structures. However, the tax burden must not be understood as a static or a fixed quantity determined in advance. This is because the design or choice of companies’ legal form can also be used as a tool to gain competitive advantages and optimise the tax burden or after-tax profit. Accordingly, the tax-optimising choice of legal form can be used as an instrument for tax planning and internal financing (reduction of tax payments and optimisation of the group tax rate). Therefore, for groups of companies and multinationals, the question that arises is how and within what limits can they make effective use of the cross-border tax rate differential, particularly through structuring their legal form. However, using cross-border tax advantages may be prevented by the controlled foreign corporation (CFC) taxation, called the Anti Tax Avoidance Directive (ATAD), which was introduced in all EU member states from 1 January 2019 onwards due to European law: Art. 7, 8 of Directive 2016/1164 to combat tax avoidance practices. In multinational companies, there is a tension between the tax-optimising choice of legal form, including the structuring of shareholdings, and CFC taxation. It is important to identify the CFC taxation requirements according to ATAD or the respective member state of residence and to avoid these requirements when structuring individual circumstances or investments. An important finding here is that the factual prerequisites for CFC taxation under ATAD are not aligned with the accounting rules, especially controlling interest and control participation. Finally, from an overall perspective, tax-optimised corporate groups’ structure or the legal architecture is not a static variable but an evolving system composed of tax-optimised sub-systems or subgroup structures. This connection between the choice of legal form, shareholding structure and the legal system, tax planning, and tax optimisation in multinational companies is analysed and evaluated based on the Austrian CFC taxation (Sec. 10a CITA) and the German CFC taxation (Sec. 7 FTTA). Furthermore, the implications for companies and society, and the legislator, are highlighted. The article also deals with the relationship between law and tax planning.


2021 ◽  
Vol 9 (1) ◽  
pp. 59-72
Author(s):  
Abid Ramadhan ◽  

This study aimed to examine the effect of growth sales and company profits on tax avoidance practices in companies listed on the Jakarta Islamic Index in period of 2015-2019. The method in this research uses a quantitative approach. Population and sample come from the annual reports of companies listed on the Jakarta Islamic index with the sample criteria that have been determined using the purposive sampling method. Data analysis using multiple linear regression. The proxy for tax avoidance practice uses the effective tax rate. The analysis results showed that the sales growth variable does not affect tax avoidance. It is caused by decreased sales growth and makes company profits. Also, the company decrease does not need to do tax avoidance. Meanwhile, company profit affects tax avoidance. It indicates that the high profit of the company will make management carry out careful tax planning. In the end, it will produce an optimal tax that will be distributed to the state.


2021 ◽  
Vol 8 (2) ◽  
pp. 28-39
Author(s):  
Nikolaos Eriotis ◽  
Spyros Missiakoulis ◽  
Ioannis Dokas ◽  
Marios Tzavaras ◽  
Dimitrios Vasiliou

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.


2014 ◽  
Vol 28 (4) ◽  
pp. 121-148 ◽  
Author(s):  
Gabriel Zucman

This article attempts to estimate the magnitude of corporate tax avoidance and personal tax evasion through offshore tax havens. US corporations book 20 percent of their profits in tax havens, a tenfold increase since the 1980; their effective tax rate has declined from 30 to 20 percent over the last 15 years, and about two-thirds of this decline can be attributed to increased international tax avoidance. Globally, 8 percent of the world's personal financial wealth is held offshore, costing more than $200 billion to governments every year. Despite ambitious policy initiatives, profit shifting to tax havens and offshore wealth are rising. I discuss the recent proposals made to address these issues, and I argue that the main objective should be to create a world financial registry.


2016 ◽  
Vol 4 (1) ◽  
pp. 873
Author(s):  
Hetti Herawati ◽  
Diah Ekawati

Abstract. For the Government, taxes are a source of the highest acceptance it is desirable at this point with the contribution of approximately 70% when compared to other admissions resources. As a major state income tax, became an extra burden for the company because it can reduce the value of the net profit of the company. Given the tax burden is to be borne by the company, then the company is working to its fullest in order to minimize the tax burden, by making tax planning. The purpose of this research is to know the influence of the tax planning of the company. by making the financial statements of PT Unilever Indonesia, Tbk. period 2006 until 2015 as objects of research.  Metode of research is kuantitatif methode,  tax planning in the count by using the calculation of the Effective tax rate on cash, long run cash effective tax rate, book a tax difference and tax sheltering activities. As for the value of the company using price earnings ratio.  Test results of Statistics 135.06 get the tax planning  influence to corporate vaue, so we accepted hipotesis Nul.Keywords: Tax Planning , Corporate Value Abstrak. Bagi pemerintah, pajak merupakan sumber penerimaan tertinggi yang sangat diharapkan pada  saat ini dengan kontribusi lebih kurang 70% bila dibanding sumber penerimaan lain. Sebagai pendapatan utama negara, pajak menjadi beban tambahan bagi perusahaan karena dapat mengurangi nilai laba bersih perusahaan. Mengingat pajak merupakan beban yang harus ditanggung oleh perusahaan, maka perusahaan berupaya semaksimal mungkin untuk dapat meminimalisir beban pajak, dengan melakukan perencanaan pajak. Tujuan dari penelitian ini adalah untuk mengetahui pengaruh perencanaan pajak terhadap nilai perusahaan. dengan menjadikan laporan keuangan PT. Unilever Indonesia,Tbk periode 2006 sampai dengan 2015 sebagai objek penelitian. Metode Penelitian yang digunakan adalah metode kuantitatif , dimana perencanaan pajak di hitung dengan menggunakan perhitungan cash Effective tax rate, long run cash effective tax rate, book tax difference dan aktifitas tax sheltering. Sedangkan untuk nilai perusahaan menggunakan price earnings ratio. Hasil uji F Statistik sebesar 135,06 menunjukan bahwa secara keseluruhan perencanaan pajak berpengaruh terhadap nilai perusahaan, sehingga hipotesis awal Ho penelitian ini. Kata Kunci: Perencanaan Pajak, Nilai Perusahaan


2020 ◽  
Vol 10 (1) ◽  
Author(s):  
Gatot Soepriyanto ◽  
Arfian Zudana ◽  
Priti Siwa Linggam

This study aims to investigate the involvement of Indonesian firms in tax haven jurisdiction and their corporate tax avoidance activities. Employing Indonesian companies listed in the Indonesia Stock Exchange and the ICIJ Offshore Leaks Database from 2005-2016, this study found that Indonesian companies with tax haven operations as documented in the offshore database have a lower Cash Effective Tax Rate (CETR) and Book Effective Tax Rate (BETR) relative to companies which presumably are unrelated to tax haven jurisdiction based on the leaks data. The results indicate that the effect of having tax haven operations is the reduction of tax payments. Furthermore, as predicted, this study found evidence that companies with tax haven operations as indicated in the ICIJ Offshore Leaks Database have higher cash holdings compared to the counterparts. In this case, those companies also have lower leverage relative to the companies without tax haven operations. Additionally, we also found that firms involved in tax haven operations have a lower return on assets and capital expenditures compared to firms that are not established in a tax haven jurisdiction. In general, those results show that by having operations in tax havens, companies can generate higher cash tax savings to be used for their operations. The findings of this study are significant to identify the characteristics attached to companies with tax haven operations and extend previous literature studies by providing evidence on the characteristics of companies in developing countries which use tax haven operations.


2021 ◽  
Vol 0 (0) ◽  
Author(s):  
Sameh Kobbi-Fakhfakh

Abstract This study examines the interplay between tax haven use, geographic disclosures and corporate tax avoidance. Based on a panel of 497 non-financial EU listed firms during the period 2006–2012, we provide evidence that corporate groups with affiliates in tax havens tend to have lower effective tax rates and lower geographic disclosures fineness scores. We, also, find a positive association between geographic disclosures fineness scores and the firms’ effective tax rates. We, further, find that the negative association between tax haven use and the effective tax rate is more pronounced for firms disclosing geographic information at a more aggregated level, showing a moderating effect of geographic disclosures fineness on such association. Our findings are based upon hand-collected data on corporate geographical dispersion, and corroborated by several additional and robustness tests. The research results should be of concern to policymakers and others interested in multinational companies’ segment reporting practices and tax planning activities.


2017 ◽  
Vol 4 (01) ◽  
Author(s):  
M. M. Sury

International tax avoidance and evasion is a serious problem in developing countries where the tax systems are still evolving. While it is true that international business operations are exposed to the risk of being subject to double taxation, such activities also provide various opportunities for tax avoidance and evasion. This paper analyses at the various methods adopted for international tax evasion and avoidance such as tax treaties, tax havens, and transfer pricing. It also examines the general causes of this evasion along with the detrimental impact that it has on the economy. In addition, it discusses the various estimates of tax evasion in India from time to time. While examining the history of taxation law amendments in India, it is seen that it is essentially a history of plugging loopholes, as and when discovered, to prevent leakages of revenue rather than making structural changes in the taxation system to strike at the root cause of the problem. India needs tougher laws and stricter enforcement of existing provisions to deal with the root causes of international tax evasion and avoidance.


2017 ◽  
Vol 32 (1) ◽  
pp. 87-104 ◽  
Author(s):  
F. Todd DeZoort ◽  
Troy J. Pollard ◽  
Edward J. Schnee

SYNOPSIS U.S. corporations have the ability to avoid paying domestic taxes to achieve an effective tax rate that is much lower than the statutory federal tax rate. This study evaluates the extent that individuals differ in their attitudes about the ethicality of corporations avoiding domestic taxes to achieve low effective tax rates. We also examine the extent to which the specific tax avoidance method used by corporations to access a low effective tax rate affects perceived ethicality. Eighty-two members of the general public and 112 accountants participated in an experiment with two participant groups and three tax avoidance methods manipulated randomly between subjects. The results indicate a significant interaction between participant group and tax avoidance method, with the general public considering shifting profits out of the country to achieve a low effective tax rate to be highly unethical, while the accountants find tax avoidance from carrying forward prior operating losses to be highly ethical. Further, mediation analysis indicates that perceived fairness and legality mediate the effects of participant type on perceived ethicality. Mediation analysis also reveals that sense of fairness and legality mediate the link between tax avoidance method and perceived ethicality. We conclude by considering the study's policy, practice, and research implications.


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