scholarly journals Do Tax Information Exchange Agreements Curb Transfer Pricing-Induced Tax Avoidance?

2017 ◽  
Author(s):  
Markus Diller ◽  
Johannes Lorenz

2018 ◽  
Vol 2 (1) ◽  
pp. 1-28
Author(s):  
Teza Deasvery Falbo ◽  
Amrie Firmansyah

The increase in tax revenue in Indonesia is not accompanied by an increase in tax ratio The low tax ratioindicatestax avoidance practices in Indonesia. Some tax avoidance practices can be conductedthrough transferpricing and thin capitalization.This study is aimed to examine empirically the effect of thin capitalization as well astransfer pricing aggressiveness on tax avoidance practice in Indonesia. This study uses manufacturing companieswhich are listed on Indonesia Stock Exchange (IDX) within the period 2013-2015. Using purposive sampling, theselected samples in this study are 90 companies, so the total sample is 270 samples. The hypothesis examinationused in this study is multiple linear regression analysis of panel data.The results of this study suggest that thincapitalization is positively associated with tax avoidance,while transfer pricing aggressivenessis not associated withtax avoidance.









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.



2020 ◽  
Vol 20 (20) ◽  
pp. 160-199
Author(s):  
封昌宏 封昌宏

受到國際反避稅、稅務金融資訊交換、國際反洗錢及中美貿易戰等因素的影響,臺灣的稅務居民已意識到,資金停留在境外不是最安全的地方,許多人想將境外的資金匯回。但要匯回資金首先要面對課稅的問題,因為這些多年來在境外所累積的資金,很可能涉及有應課稅的所得。為了迎接這波的資金匯回,財政部提出了一部專為資金匯回制定的法律,解除資金匯回的課稅疑慮。但財政部在執行面卻又顯得保守,造成申請人以扭曲的行為來適用的這部專法,造成更多的爭議問題。本文就這些爭議問題,提出評析。Under the influence of international anti-tax avoidance, tax financial information exchange, international anti-money laundering and Sino-US trade war, Taiwan’s tax residents have realized that it is not relative safer to park their funds abroad and therefore, many Taiwanese people desire to repatriate overseas funds back to Taiwan. However, we need to face the first issue of taxation of possible taxable income accumulated abroad for a long period. In order to encourage the wave of repatriated offshore funds, the Ministry of Finance has specifically proposed a law to relieve the taxation doubts on repatriated funds. In the other hand, the Ministry of Finance has imposed a conservative manner on implementation, leading to applicants’ distorted behavior to apply for this law, which evokes more controversial issues. This article presents an analysis of these controversial issues.



Author(s):  
Rebecca Reineke ◽  
Katrin Weiskirchner-Merten

This study examines how spillovers affect a multinational company's choice of an intangible's location and the corresponding transfer price for using this intangible. Our model uses a company with a domestic division in a high-tax country and a foreign division in a low-tax country, where each division's activities generate spillovers on the other division's income. In contrast to previous studies, our analysis incorporates an intangible's optimal location when the company trades off tax minimization and efficient activities. By locating the intangible abroad, the company reduces its tax liability, whereas locating the intangible domestically yields more efficient domestic division activities. For a high spillover of the domestic division, the company locates the intangible domestically. Our model supports empirical evidence regarding intangibles' location that is interpreted as "home bias". Additionally, we show how variations in regulatory parameters-arm's length range and tax rate differential-affect the divisions' activities and the intangible's location.



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