scholarly journals Benchmarking Marketing Intangibles: Need for Coordinated Transfer Pricing Regimes

2017 ◽  
Vol 3 (2) ◽  
Author(s):  
Lakshana Radhakrishnan
Keyword(s):  
Transfer Pricing ◽  
Tax Policies ◽  
Profit Shifting ◽  
International Consensus ◽  
Effective Implementation ◽  
Cross Border ◽  
Tax Regimes ◽  
Cross Country ◽  
Tax Systems ◽  
National Tax

Tax competitive policies can be effective in cases of a collaborated cross-border effort with international consensus on minimum thresholds and mechanisms for cross-country cooperation. However, aggressive uncoordinated tax competitiveness destroys value and shrinks the growth and prosperity of the industry. Hence, there is a need for tax certainty and common standards in international transfer pricing. The OECD has provided a framework for countries to move towards universal tax regimes that have common tax policies and coordinated implementation systems. This paper highlights the issue of AMP (advertising, marketing and promotion) costs in transfer pricing and seeks to establish the need for coordination among national tax systems. Ensuring consistency among the tax policies of the world’s nations is important for preventing instances of BEPS (base erosion and profit shifting) that are the products of the gaps between elaborately drafted and extremely complicated tax legislations. Creation of universal tax principles and their effective implementation is the only solution to this problem.

scholarly journals Small and medium sized enterprises (SMEs) and transfer pricing

2012 ◽  
Vol 60 (2) ◽  
pp. 349-356
Author(s):  
Veronika Solilová
Keyword(s):  
Home Country ◽  
Transfer Pricing ◽  
Internal Market ◽  
International Taxation ◽  
Member States ◽  
Compliance Costs ◽  
Cross Border ◽  
Tax Systems ◽  
Important Position ◽  
The Eu

Small and medium sized enterprises have very important position in the EU economy, mainly in the area of growth and employment. However, most of SMEs are active only in their home country and only a few of them participate in cross-border activities. Furthermore, their activities in the internal market are limited by great deal of obstacles, mainly in the form of different tax systems which generate excessive compliance costs of taxation and the existence of different SMEs definitions for various purposes in Member states. In addition, from the view of the international taxation issues, the most important obstacles can be considered a transfer pricing and cross-border loss compensations. In this area, SMEs are facing specific problems and have specific needs. The aim of the paper is to analyze and evaluate the specific transfer pricing issues of SMEs and propose recommendations for them.

scholarly journals The EU financial transactions tax: Antecedents and current debate

2013 ◽  
Vol 60 (3) ◽  
pp. 311-321 ◽  
Author(s):  
Yiannis Kitromilides ◽  
Ana González
Keyword(s):  
Financial Sector ◽  
Current Debate ◽  
Tobin Tax ◽  
Cross Border ◽  
Tax Systems ◽  
Global Coordination ◽  
National Tax ◽  
The Uk ◽  
Financial Transactions ◽  
The Eu

The paper deals with the development of the Financial Transactions Tax (FTT) policy idea and its feasibility in the absence of global coordination. New taxes are evaluated in terms of how they fit into existing national tax systems. Increasingly, however, cross-border issues assume greater significance in tax design and this is particularly pertinent in the case of FTT which has a long history. The various changes in tax systems and the economic environments within which they operate since the original ?Tobin Tax? proposal are noted and the way they affect the debate on FTT are discussed. The proposal to introduce a unilateral FTT in the EU and its feasibility are examined. In terms of achieving its fundamental objectives the feasibility of the tax is crucial unless, as may be the case in the UK, the need to rebalance the economy away from the financial sector is a more urgent priority.

scholarly journals Substitution across profit shifting methods and the impact on thin capitalization rules

2021 ◽  
Author(s):  
Gideon Goerdt ◽  
Wolfgang Eggert
Keyword(s):  
Multinational Firms ◽  
Transfer Pricing ◽  
Multinational Firm ◽  
Profit Shifting ◽  
Goods And Services ◽  
Internal Goods ◽  
Transfer Prices ◽  
Debt Shifting ◽  
The Impact ◽  
Thin Capitalization

AbstractThin capitalization rules limit firms’ ability to deduct internal interest payments from taxable income, thereby restricting debt shifting activities of multinational firms. Since multinational firms can limit their tax liability in several ways, regulation of debt shifting may have an impact on other profit shifting methods. We therefore provide a model in which a multinational firm can shift profits out of a host country by issuing internal debt from an entity located in a tax haven and by manipulating transfer prices on internal goods and services. The focus of this paper is the analysis of regulatory incentives, $$(i)$$ ( i ) if a multinational firm treats debt shifting and transfer pricing as substitutes or $$(ii)$$ ( i i ) if the methods are not directly connected. The results provide a new aspect for why hybrid thin capitalization rules are used. Our discussion in this paper explains why hybrid rules can result in improvements in welfare if multinational firms treat methods of profit shifting as substitutes.

scholarly journals Research on Cross-Border Emergency Logistics Collaboration Mechanism under the Background of Belt One Road Initiative

2020 ◽  
Vol 5 (4) ◽  
pp. 256
Author(s):  
Jiangze Zhang
Keyword(s):  
Coordination Mechanism ◽  
Management Systems ◽  
Logistics System ◽  
Effective Implementation ◽  
Cross Border ◽  
Emergency Logistics ◽  
Depth Analysis ◽  
Special Part ◽  
Belt And Road ◽  
The Belt And Road

<p>Emergency logistics is a special part of the logistics system. When emergencies occur, emergency logistics is indispensable. Currently, the current situation of cross-border emergency logistics has many drawbacks. In order to further reduce the losses caused by emergencies, it is necessary to improve the cross-border emergency logistics system, in-depth analysis of the current problems in the four aspects of cross-border logistics management, systems, logistics information, and material distribution in countries along the Belt and Road Initiative, through the establishment of a cross-border emergency logistics coordination mechanism, relevant strategies are established to ensure the effective implementation of emergency logistics.</p>

Globalization and U.S. Corporate Tax Policies: Evidence from Import Competition

2021 ◽  
Author(s):  
Tao Chen ◽  
Chen Lin ◽  
Xiang Shao
Keyword(s):  
Natural Experiment ◽  
Transfer Pricing ◽  
Manufacturing Firms ◽  
Import Competition ◽  
Tax Policies ◽  
Corporate Tax ◽  
Trade Relations ◽  
Trade Dispute ◽  
China Trade ◽  
Tax Reduction

This paper studies how globalization affects the corporate tax policies of U.S. manufacturing firms. Using U.S.-granting China Permanent Normal Trade Relations as a quasi-natural experiment, we find a significant increase in tax reduction activities for firms facing higher exposure to Chinese imports. The effect is more pronounced for firms with higher managerial slack. We also find that the effect is stronger for firms in less diversified products market and faster changing industries. We also show that U.S. firms facing higher Chinese import competition are more likely to engage in other tax-motivated activities: acquisition of subsidiaries in low-tax regions and suspected transfer pricing. Furthermore, we explore the 2017 tax cut and the recent U.S.-China trade dispute and find that firms engage less in tax reduction activities after the 2017 tax cut and after the tariff increase for Chinese imports. This paper was accepted by Kay Giesecke, finance.

Analysis of the Theory of Cycle of Money

2020 ◽  
Vol 23 (2) ◽  
pp. 13-29
Author(s):  
Constantinos Challoumis
Keyword(s):  
Social Welfare ◽  
Tax Policy ◽  
Small And Medium Enterprises ◽  
Transfer Pricing ◽  
Well Being ◽  
Tax Policies ◽  
Know How ◽  
Medium Enterprises ◽  
Econometric Approach ◽  
Positive Effect

Abstract This study investigates the Theory of Cycle of Money. The concept of this theory is based on the distribution of money in an economy and shows that it is plausible to have a positive effect on an economy by the appropriate public and tax policy (when is applied the cycle of money). The dynamic of each economy is represented by the concept of the cycle of money. The multiple times that money is used and reused to a country’s economy, without getting out to external economies and banking systems, clarifies the robustness of this economy. Therefore, to this analysis are determined the appropriate tax policies in connection with the savings of the companies of controlled (the companies of transfer pricing administrate their taxation with the allocation of profits and losses to maximize their benefits) and uncontrolled transactions (the companies are not participating in allocations to administrate their profits and losses). This theory is based on the approach that small and medium enterprises must have lower taxes than larger and international companies that substitute the activities of these companies. Moreover, the only large economic units that should have low taxes are the factories and know-how technological companies. In that way, a society could achieve its best well-being standards, as this is a theory that completely sought social welfare. This article aims to clarify the Theory of Cycle of Money and its importance for the robustness of the economy, and the prosperity of the society and citizens. The current study applies the Q.E. method and its econometric approach.

Simplification in Transfer Pricing

2021 ◽  
Vol 22 (3) ◽  
Author(s):  
Aitor Navarro
Keyword(s):  
Developing Countries ◽  
International Organizations ◽  
Transfer Pricing ◽  
Policy Option ◽  
Profit Shifting ◽  
Accepted Standard

It is the aim of this contribution to sustain that, despite the inherent complexity that the enforcement of the arm’s length rationale entails, it is feasible—and desirable—to introduce simplification measures without abandoning this worldwide accepted standard, especially in the context of developing countries and despite reticence shown by international organizations such as the OECD. Complexity in transfer pricing erodes fairness and equity and promotes profit shifting, which paradoxically constitutes the opposite outcome that this set of rules wants to achieve. This is the reason why it is urgent to propose and encourage the adoption of a means to neutralize unnecessary complexity in this field. The adoption of rebuttable predetermined margins and/or methods is proposed as the best solution in a context in which policymakers want to keep the arm’s length rationale intact. Also, even despite its shortcomings, irrebuttable predetermined safe harbors should be considered potentially feasible and a valid policy option.

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