Corporate Tax Act Issues Related to the Assessment of the Brand Royalties Applied to the Intra-Group Transactions of the Corporate Group -Focusing on the Treatment of the Factor “Profit Arising from the Intro-Group Transactions”-

2019 ◽  
Vol 25 (3) ◽  
pp. 583-624
Author(s):  
Hyojung Bae
2018 ◽  
Vol 27 (6) ◽  
pp. 361-399
Author(s):  
Ji Myung Han ◽  
Jinbae Kim
Keyword(s):  
Tax Law ◽  

Author(s):  
Igor Semenenko ◽  
Junwook Yoo ◽  
Parporn Akathaporn

Growing tax competition among national governments in the presence of capital mobility distorts equilibrium in the international corporate tax market. This paper is related to the literature that examines impact of international tax policies on corporate accounting statements. Employing international firm-level data, this study revisits the race-to-the-bottom hypothesis and documents that tax exemptions lowering effective tax rates relative to statutory rates increase pre-tax returns. This finding directly contradicts the implicit tax hypothesis documented by Wilkie (1992), who provided empirical evidence on inverse relationship between pre-tax return and tax subsidy. We also find evidences that relative importance of permanent versus timing component depends on the geography and that decline in corporate tax rates reduces impact of tax subsidies on profitability. Our findings suggest that tax subsidies play a different role than in 1968-1985, which was examined by Wilkie (1992). These results are consistent with the race-to-the-bottom hypothesis and income shifting explanation


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