Geographic Income Shifting by Multinational Corporations in Response to Tax Rate Changes

1993 ◽  
Vol 31 ◽  
pp. 141 ◽  
Author(s):  
Kenneth Klassen ◽  
Mark Lang ◽  
Mark Wolfson
Keyword(s):  
Multinational Corporations ◽  
Income Shifting ◽  
Tax Rate

A Model of Multinational Income Shifting and an Application to Tax Planning with E-Commerce

2014 ◽  
Vol 36 (2) ◽  
pp. 27-53 ◽  
Author(s):  
Kenneth J. Klassen ◽  
Stacie K. Laplante ◽  
Carla Carnaghan
Keyword(s):  
Tax Planning ◽  
Investment Model ◽  
Income Shifting ◽  
Tax Rates ◽  
Foreign Investments ◽  
Effective Tax Rates ◽  
Tax Rate ◽  
Foreign Earnings ◽  
Joint Consideration ◽  
The U.S

ABSTRACT: This manuscript develops an investment model that incorporates the joint consideration of income shifting by multinational parents to or from a foreign subsidiary and the decision to repatriate or reinvest foreign earnings. The model demonstrates that, while there is always an incentive to shift income into the U.S. from high-foreign-tax-rate subsidiaries, income shifting out of the U.S. to low-tax-rate countries occurs only under certain conditions. The model explicitly shows how the firms' required rate of return for foreign investments affects both repatriation and income shifting decisions. We show how the model can be used to refine extant research. We then apply it to a novel setting—using e-commerce for tax planning. We find firms in manufacturing industries with high levels of e-commerce have economically significant lower cash effective tax rates. This effect is magnified for firms that are less likely to have taxable repatriations. JEL Classifications: G38, H25, H32, M41.

Security Analyst and Stock Market Efficiency in Anticipating Tax-Motivated Income Shifting

2006 ◽  
Vol 81 (1) ◽  
pp. 227-250 ◽  
Author(s):  
Philip B. Shane ◽  
Toby Stock
Keyword(s):  
Earnings Forecasts ◽  
Income Shifting ◽  
Market Prices ◽  
Tax Rate ◽  
Income Effects ◽  
Market Participants ◽  
Security Analyst ◽  
Market Inefficiency ◽  
Reported Earnings ◽  
Statutory Tax Rate

In the context of the statutory tax rate reductions enacted in the Tax Reform Act of 1986, this paper investigates the degree to which capital market participants anticipate and correctly interpret temporary income effects of tax-motivated income shifting. We find evidence consistent with financial analysts' earnings forecasts failing to anticipate earnings management that shifts income from fourth quarters in higher tax rate years to immediately following first quarters of lower tax rate years. The evidence suggests that this failure is not the result of a decision to ignore the income shifting, but rather an inability to recognize temporary components of reported earnings. We also find evidence that market prices do not fully reflect the temporary income effects of tax-motivated income shifting, and that analyst inefficiency explains about half of the market inefficiency. We interpret these inefficiencies as potentially important costs of tax planning that could limit the ability of public firm managers to implement otherwise optimal tax strategies.

scholarly journals Corporate Income Shifting in an Era of Tax Multilateralism: The Impact of Exchange-of-Information Agreements

2021 ◽  
Vol 69 (2) ◽  
pp. 357-389
Author(s):  
Devan Mescall ◽  
Paul Nielsen
Keyword(s):  
Multinational Corporations ◽  
Multinational Enterprises ◽  
Transfer Pricing ◽  
Empirical Studies ◽  
Annual Reports ◽  
Income Shifting ◽  
Exchange Of Information ◽  
Pricing Rules ◽  
Using Data ◽  
The Impact

Using data from the annual reports of over 100,000 subsidiaries of multinational enterprises (MNEs) from 55 countries between 2003 and 2012, the authors of this article investigate the impact of exchange-of-information agreements ("EOI agreements") on tax-motivated income shifting. Transparency created by the signing of EOI agreements is expected to reduce the tax-motivated shifting of income by multinational corporations. Whether such agreements affect the income-shifting behaviour of multinational corporations is an unanswered question. The authors find evidence that, on average, EOI agreements do have an impact on tax-motivated income shifting. Additionally, they find that more advanced, modern EOI agreements are associated with a larger decrease in tax-motivated income shifting compared to the impact of early EOI agreements. This evidence challenges the prevalent assumption in empirical studies that EOI agreements are homogeneous. Supplemental analyses suggest that factors that affect the information asymmetry between MNEs and tax authorities, such as corporations with high levels of intangibles and tax authorities with strong transfer-pricing rules and enforcement, can diminish or enhance the effectiveness of EOI agreements in moderating tax-motivated income shifting. The evidence provided by this study shows that consideration of the tax authorities' information environment and the substance of an EOI agreement is essential when assessing the impact of such an agreement on the tax behaviour of sophisticated taxpayers such as multinational corporations.

scholarly journals PENGARUH TARIF PAJAK PENGHASILAN, MEKANISME BONUS, DAN TUNNELING INCENTIVES TERHADAP PERGESERAN LABA DALAM MELAKUKAN TRANSFER PRICING DENGAN GOOD CORPORATE GOVERNANCE SEBAGAI VARIABEL MODERASI

2019 ◽  
Vol 4 (2) ◽  
pp. 141
Author(s):  
Vinola Herawaty ◽  
Anne Anne
Keyword(s):  
Corporate Governance ◽  
Income Tax ◽  
Audit Quality ◽  
Transfer Pricing ◽  
Income Shifting ◽  
Manufacturing Companies ◽  
Tax Rate ◽  
Independent Variables ◽  
Good Corporate Governance ◽  
Bonus Plan

<p><em>This study aims to examine the effect of income tax rates, bonus plan and tunneling incentives as instruments in detecting income shifting with transfer pricing with moderate good corporate governance. The independent variables in this research are income tax rate, bonus plan and tunneling incentives as well as leverage and firm size as control variables. Good corporate governance mechanism that has been used in this research is audit quality regarding to auditor reputation.The sample was taken by purposive sampling method consisting of 176 manufacturing companies of consumer goods industry sector listed in Indonesia Stock Exchange which have reported complete financial report in period 2013-2016. Test of hypothesis was using SPSS 23 application.The results show that good corporate governance has weaken positive significant for bonus plan and tunneling incentives in detecting income shifting in transfer pricing. Meanwhile, other independent variables income tax rate has no significant effect. </em></p>

International income shifting by US multinational corporations

1997 ◽  
Vol 29 (7) ◽  
pp. 925-934 ◽  
Author(s):  
Donald J. Rousslang
Keyword(s):  
Multinational Corporations ◽  
Income Shifting

Methodological problems of BEPS analysis

2021 ◽  
Vol 2021 (6) ◽  
pp. 55-71
Author(s):  
Olga IVANYTSKA ◽  
◽  
Tetiana KOSCHUK ◽  
Keyword(s):  
Multinational Corporations ◽  
Empirical Studies ◽  
Limited Information ◽  
Sources Of Information ◽  
Economic Activities ◽  
Effective Tax Rate ◽  
Profit Shifting ◽  
Tax Rate ◽  
High Profit ◽  
Profit Rates

The article is devoted to the issues of the methodology of the analysis of the base erosion and profit shifting (BEPS) for the development of managerial approaches to counteracting these destructive phenomena in Ukraine. Eleven types of data sources identified by the OECD that can be used for BEPS analysis are determined. It is shown that most sources of information for the purposes of analyzing the scale and effects of BEPS have significant limitations: their absence or limited representativeness in some countries; regulatory restrictions on access to data; lack of most financial data to reflect the activities of multinational corporations (MNCs). The indicators that testify to BEPS or dangerous phenomena of financial abuse, which are reflected in reporting, are analyzed, namely: 1) disconnect between financial and real economic activities; 2) high profit rates of low-taxed affiliates of top global MNCs; 3) high profit rates of MNC affiliates in lower-tax locations; 4) MNCs vs. "comparable" non-MNC effective tax rate differentials; 5) profit shifting through intangibles; 6) profit shifting through interest. It is proved that for Ukraine the calculation of a number of indicators can be complicated due to the delay in the publication of official data; lack of appropriate statistical reporting. In general, indicators show that they provide limited information about financial transactions and cannot reliably relate any changes and their reflection to BEPS. Therefore, the implementation of measures to combat BEPS should be based not only on the results of calculations of OECD indicators, but also on other empirical studies that provide reliable information on the development of income transfer between countries.

scholarly journals Abuses and Penalties of a Corporate Tax Inversion

2019 ◽  
Vol 7 (1) ◽  
pp. 5
Author(s):  
James Yang ◽  
Leonard Lauricella ◽  
Frank Aquilino
Keyword(s):  
Multinational Corporations ◽  
International Taxation ◽  
Internal Revenue Service ◽  
Tax Law ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Tax Savings ◽  
Treasury Department ◽  
The U.S

There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S. has been seriously eroded. This practice is known as “corporate tax inversion”. This paper discusses the abuses and penalties of this phenomenon. It is rooted in some deficiencies in the U.S. tax law. This paper points out that the U.S. has the highest corporate tax rate in the world. It imposes tax on worldwide income. It permits deferral of tax on foreign-sourced income until dividends are repatriated back to the U.S. As a result, it creates tax loopholes. This paper reveals six actual cases of corporate tax inversion. This practice has triggered the Congress to enact §7874, the Internal Revenue Service (IRS) to issue Notices IR 2014-52 and IR 2015-79, and the U.S. Treasury Department to promulgate TD 9761. This paper investigates some details of these penalties. This paper further demonstrates an example in determining the amount of tax savings by engaging in a corporate tax inversion. It also offers many strategies.

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