scholarly journals Assessment of Measures for Tax Regulation of Transfer Pricing from the Standpoint of National Welfare

2020 ◽  
Vol 14 (1) ◽  
pp. 80-90
Author(s):  
Liudmila Polezharova
Keyword(s):  
Transfer Pricing ◽  
Tax Planning ◽  
International Taxation ◽  
Actual Mechanism ◽  
National Welfare ◽  
The Government ◽  
Scientific Challenge ◽  
National Economies ◽  
National Governments ◽  
Tax Regulation

This article is devoted to development of mathematical models for resolving an actual scientific challenge in the field of corporate finance. This involves substantiating taxation policies for the counter-acting tax planning of multinational companies (MNC), and then devising and articulating the appropriate international taxation scheme, as evaluated from the position of national welfare policy. Based on an analysis of existing models of international taxation, and on the peculiarities of the actual mechanism of capital movement tax regulation, new models with equilibrium postulated have been developed. The primary mechanisms of this research involve the following considerations: (1) examination of an approach targeted at the determination of the final outcomes of international taxation from the perspective of national economies; (2) measures of tax planning on the part of MNCs, and corresponding counter-acting measures to the tax planning applied by governments, are taken as a complex. Our results indicate that because a government uses rules of controlled transactions, in order to counter-act MNCs’ tax planning, for the government the final outcome from an application of these rules may be negative. This is due to a possibility of MNCs’ development in convenient and offshore jurisdictions. This finding is illustrated by means of an approbation of models with a case study involving a three-tier structure.Further to this point, instead of additional revenues, a government is at a risk of a shrinking tax base and a reduction in budget revenues; and moreover from the perspective of national welfare, the additional loss of revenues and capital of MNCs. Therefore there is a significant importance in forming rules for MNC taxation policies which would focus not on taxes as such, but would focus on trying to keep capital within the territory and/or would facilitate the return of earlier divested income. This could be attempted, for example, by using the secondary adjustment rule in conjunction with a minimum tax on return. The novelty of this research resides in the specificity of our investigation and the applicability of our conclusions to the practical challenges of international taxation and national revenue policies. The peculiarities of this economic moment and the crucial challenges for national governments in dealing with MNCs and the digital economy underline the significance of this study. Our results expand and develop the existing literature in this ever-crucial area be of immediate use to policymakers, academics and administrators involved in national and international taxation, finance, economics, and analysis.

scholarly journals International tax models towards multinational companies from the perspective of national welfare

2020 ◽  
Vol 11 (29) ◽  
pp. 337-366 ◽  
Author(s):  
L.V. Polezharova ◽  
M.A. Goncharenko ◽  
A.V. Gryechishkin
Keyword(s):  
Level Structure ◽  
Multinational Companies ◽  
Tax Planning ◽  
International Taxation ◽  
Tax Base ◽  
The Real ◽  
National Welfare ◽  
Scientific Task ◽  
The Government ◽  
National Economies

The article is dedicated to the development of mathematical models to solve the real scientific task of supporting tax policies for counter-acting tax planning of multinational companies (MNCs) that are working in the field of production and engineering, forming the scheme international prosecutor, from the position of national welfare. Based on the analysis of the existing models of international taxes and on the peculiarities of the real mechanism of tax regulation of capital movement, new models have been developed with a balance orientation. The main points for this balance are: a) an approach aimed at determining the final results of international taxation from the perspective of national economies; b) Take as an example the gap between tax planning measures by multinationals and measures contrary to government tax planning. The approval of models with the case study of the multi-level structure in which, to counteract the tax planning of multinational companies, the Government uses rules of controlled transactions, demonstrated that due to the possibility of development of multinational companies in convenient and extraterritorial jurisdictions, for Government the final result of the application of these rules can be negative. Instead of additional income, you risk reducing the tax base and reducing budget income; And from the perspective of national welfare, this implies losing the income and capital of multinational companies. It is considered important that the rules for the taxation of multinational companies should not focus on taxes as such, but should encourage the maintenance of capital within the territory or facilitate the return of previously disinvested income.

Taxes, Transfer Pricing, and The Multinational Enterprise

2009 ◽  
Author(s):  
Lorraine Eden
Keyword(s):  
United States ◽  
Multinational Enterprises ◽  
Transfer Pricing ◽  
Multinational Enterprise ◽  
The United States ◽  
International Taxation ◽  
Complex Issue ◽  
Daunting Task ◽  
National Governments

For more than ten years now, transfer pricing has been the top international taxation issue faced by multinational enterprises (MNEs). This article aims to outline, for the reader, the complex issue of transfer pricing, as seen by MNE managers and by governments faced with the daunting task of taxing business profits. The article is organized as follows. First, it briefly discusses transfer pricing from the MNE's perspective and the problems that this raises for national governments. It then reviews the basic rules of international taxation as they apply to MNE profits. The specific rules and procedures that apply to transfer pricing, as practiced in the United States and recommended by the OECD, are then outlined. It concludes with a discussion of unresolved problems that are likely to plague transfer pricing over the next few years.

The ‘Pillared-Privatisation’ of Pension Provision in the European Union: The Case of the United Kingdom

2002 ◽  
Vol 4 (1) ◽  
pp. 5-24 ◽  
Author(s):  
Patrick Ring ◽  
Roddy McKinnon
Keyword(s):  
European Union ◽  
World Bank ◽  
The European Union ◽  
Means Testing ◽  
The Road ◽  
The United Kingdom ◽  
The World Bank ◽  
The Government ◽  
The Uk ◽  
National Governments

Across the European Union, national governments are re-assessing the institutional mechanisms through which pension provision is delivered. This articles sets the debate within the wider context of the ‘pillared’ structural analysis often adopted by international institutions when discussing pensions reform. It then sets out a detailed discussion of developments in the UK, arguing that the UK is moving towards a model of reform akin to that promoted by the World Bank – referred to here as ‘pillared-privatisation’. The themes of this model indicate more means-testing, greater private provision, and a shift of the burden of risk from the government to individuals. An assessment is then made of the implications of UK developments for other EU countries. It is suggested that while there are strong reasons to think that other countries will not travel as far down the road of ‘pillared-privatisation’ as the UK, this should not be taken as a ‘given’.

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 IPTEKS SPT MASA PAJAK PERTAMBAHAN NILAI (PPN) PADA PT CIPUTRA INTERNASIONAL CABANG MANADO

2018 ◽  
Vol 2 (02) ◽  
Author(s):  
Arisna J. Mantiaha ◽  
Syermi Mintalangi
Keyword(s):  
Value Added ◽  
Director General ◽  
Value Added Tax ◽  
The People ◽  
The Government ◽  
Tax Reporting ◽  
Is Value ◽  
Tax Regulation

Tax is a contribution from the people to the country. Every taxable entrepreneurs report tax reports to the government. One of them is Value Added Tax (VAT). PT Ciputra Internasional Manado report it’s Periodic Tax Return of VAT using e-Invoice provided by the Director General Tax. E-Invoice own application used by taxable entrepreneur in carrying out tax obligation. This study wants to provide knowledge in the application of e-Invoice to reporting VAT’s periodic tax return. Result of this research showed that PT Ciputra Internasional Manado in reporting Periodic Tax Return of VAT compliance with UU No.42 of 2009, Director General of Tax Regulation No. PER-31/PJ/2017, and Director General of Tax Regulation No.  PER-01/PJ/2017.Keywords : Value Added Tax, Reporting, E-Invoice

scholarly journals TAX HEAVENS PHENOMENON: TAX PLANNING STRATEGY OR TAX AVOIDANCE

2020 ◽  
Vol 4 (1) ◽  
pp. 1-24
Author(s):  
Dinik Fitri Rahajeng Pangestuti ◽  
Nisrina Sari ◽  
Ambar Lestari
Keyword(s):  
Data Exchange ◽  
Tax Avoidance ◽  
Tax Planning ◽  
The Other ◽  
Planning Strategy ◽  
Exchange Of Information ◽  
Small Countries ◽  
Negative Effect ◽  
The Government ◽  
Fiscal Authority

Abstract Tax planning is one example of the use of regulatory loopholes. On the other hand for the Fiscal Authority, carrying out tax avoidance practices as a form of tax planning will have a negative effect on the Government and, for this reason, the Government makes fiscal corrections as its remedial. Many also hide their assets in tax heavens countries. This is so that the assets they have are not taxed. Tax heavens countries are usually small countries that apply very low taxes, some even do not impose taxes at all. However, the government has prepared an Automatic Exchange of Information (AEoI) data exchange plan that occurs in 2018, certainly will make tax evaders unable to run away from the pursuit of the tax authorities, even if they have to flee to tax heavens countries (tax heavens). Keywords: tax heavens, tax planning, Automatic Exchange of Information (AEoI)   Abstrak Perencanaan pajak adalah salah satu contoh penggunaan celah peraturan. Pada sisi lain bagi Otoritas Fiskal, melakukan praktik penghindaran pajak sebagai bentuk perencanaan pajak akan membawa efek negatif bagi Pemerintah dan, untuk itulah, Pemerintah melakukan koreksi fiskal sebagai remedialnya. Banyak juga yang menyembunyikan asetnya di negara-negara tax heavens. Hal ini bertujuan agar aset yang mereka punya tidak terkena pajak. Negara tax heavens biasanya merupakan negara kecil yang menerapkan pajak yang sangat rendah, bahkan ada yang tidak mengenakan pajak sama sekali. Namun, pemerintah telah menyiapkan Rencana pertukaran informasi data perbankan secara otomatis (Automatic Exchange of Information/AEoI) yang terjadi pada 2018, dipastikan akan membuat para pengemplang pajak tidak akan bisa lari dari kejaran otoritas pajak, sekalipun mereka harus kabur ke negara surga pajak (tax heavens). Kata kunci: Tax Heavens, Tax Planning, Automatic Exchange of Information (AEoI)

New tools for developing the living environment (based on materials of Gaidar Forum – 2021)

2021 ◽  
Vol 23 (1) ◽  
pp. 6-12
Author(s):  
NATALYA YASKOVA ◽  
Keyword(s):  
Information And Communication Technologies ◽  
Business Models ◽  
Communication Technologies ◽  
Living Environment ◽  
Investment Activity ◽  
New Business ◽  
Information And Communication ◽  
The Government ◽  
National Economies ◽  
Expert Community

The pandemic has become the reason for structural reforms as well as for discussing many issues by the expert community. In this regard, the Gaidar Forum – 2021 became the very platform where experts in various fields of knowledge could meet. Specialists discussed such issues as sustainable development problems, the innovative focus of development, the introduction of IT technologies, restructuring of national economies, new business models, etc. Most of the questions, one way or another, concern the problem of the evolution of the living environment. These are the questions that were presented by the experts of the “Building together” discussion platform. Analyzing the results of the construction complex, which ensures the implementation of the national project “Housing and the Urban Environment”, made it possible to identify the nature of further measures taken by the Government of the Russian Federation in order to create a competitive living environment. Experts systematized the prospects for business models of investment and construction activities involved in the development of territories, identified new tools for enhancing investment activity, and focused the attention of the authorities on information and communication technologies used in modeling the living environment.

The Social Cost of International Investment Agreements: The Case of Cigarette Packaging

2018 ◽  
Vol 32 (2) ◽  
pp. 153-167 ◽  
Author(s):  
Jennifer L. Tobin
Keyword(s):  
Latin American ◽  
Multinational Firms ◽  
Well Being ◽  
International Investment ◽  
High Profile ◽  
Regulatory Changes ◽  
International Investment Agreements ◽  
The Government ◽  
National Governments ◽  
Investment Agreements

AbstractNational governments have signed and ratified over three thousand International Investment Agreements (IIAs), which for the first time give multinational firms standing to sue host governments in international arbitration tribunals. IIAs have led to a host of high-profile and controversial legal disputes that have led to claims that investor state arbitration may be impeding governments in their ability to regulate and to protect their citizens’ well-being, a phenomenon known as “regulatory chill.” To understand the normative implications of regulatory chill, I analyze investor state arbitration over tobacco in Australia and Latin America. I examine legislative discussions over possible regulatory changes in Australia and Uruguay, the two cases that have faced disputes over tobacco laws, as well as in Latin American countries that provide access to the legislative debates and had legislative initiatives that sought to strengthen tobacco legislation. These cases demonstrate that tobacco packaging laws in a number of countries have been delayed or reduced as a result of fears of potential arbitration among the government and legislators. This regulatory chill is normatively problematic as it suggests that states may be giving up more of their regulatory authority than they initially believed they would have to under IIAs.

scholarly journals Politically Connected Independent Directors and Effective Tax Rates in China

2017 ◽  
Vol 9 (1) ◽  
pp. 333 ◽  
Author(s):  
Hong Fan ◽  
Liqiang Chen
Keyword(s):  
Tax Planning ◽  
Political Connections ◽  
Independent Directors ◽  
The Political ◽  
Tax Rates ◽  
Potential Cost ◽  
Effective Tax Rates ◽  
Public Firms ◽  
The Government ◽  
Chinese Public

This paper empirically investigates politically connected independent directors in Chinese public firms using 200 state-owned enterprises (SOEs) and 200 non-SOEs from 2002–2014. We find that, in general, firms with politically connected independent directors have higher effective tax rates than firms without such directors. We argue this is because that politically connected independent directors work for the interests of the government and restrict firms’ tax planning activities. Additionally, the effect of politically connected directors on tax rates is weaker in SOEs than in non-SOEs, possibly because of the redundancy of the political ties that both independent directors and ownership bring in SOEs. Our study reveals the potential cost of political connections that prior studies have overlooked. 

Sign in / Sign up

Export Citation Format

Share Document