scholarly journals Anti Profit-Shifting Rules and Foreign Direct Investment

2014 ◽  
Author(s):  
Thiess Buettner ◽  
Michael Overesch ◽  
Georg Wamser
2021 ◽  
Vol 57 (2) ◽  
pp. 177-193
Author(s):  
Marcin Jamroży ◽  
Magdalena Janiszewska

Abstract The paper aims to identify the significant tax barriers to foreign direct investment (FDI) in Poland, in particular in the form of a permanent establishment (PE), in the context of new developments in international tax law. Due to the recommendations of the Base Erosion and Profit Shifting (BEPS) project, launched by Organisation for Economic Co-operation and Development (OECD) to prevent international tax avoidance, the understanding of PE has changed, which could lead to changes in business models. The purpose of the research is also to identify the significant tax barriers to economic activity in Poland, in particular in the form of PE, against the international tax law context. The study conducted by the authors relies on the most current tax rulings and judgments of administrative courts issued between 2017 and 2020. It is concluded that not so much the effective tax burdens but the regulatory ambiguity surrounding the tax obligations may contribute to the reduction of Poland's attractiveness as a location for FDI.


2017 ◽  
Vol 25 (3) ◽  
pp. 553-580 ◽  
Author(s):  
Thiess Buettner ◽  
Michael Overesch ◽  
Georg Wamser

2021 ◽  
Author(s):  
Paul Missios ◽  
Halis Murat Yildiz ◽  
Ida Ferrara

We use a simple two-country oligopoly model of intra-industry trade to examine the implications of foreign direct investment for the pollution haven hypothesis and environmental policy. Countries which lower environmental standards to be more competitive in world markets generate pollution havens if environmental policy is exogenous. However, if FDI is a viable option as a mode of entry, profit-shifting considerations weaken in favour of environmental considerations and FDI recipients tighten environmental policy, reducing incentives to relocate production. Interestingly, when countries are sufficiently similar in their environmental awareness, "grey" countries can become greener than originally "green" countries but firms in the latter still engage in FDI in the former, in spite of the stricter standard they face, in order to level the playing field. We derive conditions under which FDI-receiving countries have incentives to manipulate their environmental standards to prevent or attract FDI, potentially eliminating or creating pollution havens.


2021 ◽  
Author(s):  
Paul Missios ◽  
Halis Murat Yildiz ◽  
Ida Ferrara

We use a simple two-country oligopoly model of intra-industry trade to examine the implications of foreign direct investment for the pollution haven hypothesis and environmental policy. Countries which lower environmental standards to be more competitive in world markets generate pollution havens if environmental policy is exogenous. However, if FDI is a viable option as a mode of entry, profit-shifting considerations weaken in favour of environmental considerations and FDI recipients tighten environmental policy, reducing incentives to relocate production. Interestingly, when countries are sufficiently similar in their environmental awareness, "grey" countries can become greener than originally "green" countries but firms in the latter still engage in FDI in the former, in spite of the stricter standard they face, in order to level the playing field. We derive conditions under which FDI-receiving countries have incentives to manipulate their environmental standards to prevent or attract FDI, potentially eliminating or creating pollution havens.


2019 ◽  
Vol 19 (213) ◽  
Author(s):  
Ruud A. Mooij ◽  
Li Liu ◽  
Dinar Prihardini

Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative to the current international tax regime that is based on separate accounting. It highlights major advantages, such as the elimination of profit shifting within multinational groups; and it discusses new distortions and the impact on tax competition. The analysis exploits different datasets to assess the direct revenue implications for individual countries under alternative formulas. The distributional effects across countries are found to be large, reflecting major discrepancies between where profits are currently attributed and where factors of production are located or sales take place. The largest losses appear in investment hubs (i.e. countries with a disproportionate ratio of foreign direct investment to GDP), while several large advanced countries are likely to gain. Developing countries gain most likely if employment receives a large weight in the formula; they also tend to benefit, on average, from a formula based on sales by destination.


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