scholarly journals International Tax Planning: Transfer Pricing and Transactions Between Foreign Entities

2019 ◽  
Vol 67 (1) ◽  
pp. 187-208
Author(s):  
Byron Beswick
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.


Author(s):  
Arthur J. Cockfield

This chapter looks at exchange of information (EOI) policies, proposing several ways to make EOI policies fairer and more efficient, so as to maximize their potential to reduce illicit financial flows and curb abusive tax practices that undermine human rights. While there appears increasing policy and academic support for EOI initiatives that promote global financial transparency, the current international tax regime, with its high transaction costs for taxpayers and tax authorities, does not seem particularly amenable to producing optimal outcomes. The chapter then emphasizes how, to promote enforceability, the ideal EOI system delivers high-quality tax information while providing needed legal protections for taxpayer privacy. The exchange and usage of high-quality tax information would reduce transaction costs for tax authorities as they could more readily identify taxpayers engaged in offshore tax evasion and aggressive international tax planning.


2018 ◽  
Vol 58 (2) ◽  
pp. 501
Author(s):  
Sarah Blakelock ◽  
George Hempenstall

Multinationals are under increasing scrutiny by revenue authorities across the globe. The heightened risk of tax audits, transfer pricing adjustments and the potential for double taxation mean that it is more important than ever for multinationals to consider what strategies are available to resolve international tax disputes. Inherent tax risk and uncertainty creates unique challenges for oil and gas multinationals as it can impact on deal value where double taxation arises. This is because countries are increasingly behaving like companies – competing to preserve and defend their tax base. With the Organisation for Economic Co-operation and Development’s (OECD’s) Multilateral Instrument pending ratification by the Australian Parliament, this paper considers the availability and practical use of the mutual agreement procedure (MAP) for the resolution of double taxation. Additionally, the paper provides an overview of which jurisdictions have opted to adopt arbitration as a mechanism to resolve double taxation disputes where the MAP has failed.


2020 ◽  
Vol 15 (1) ◽  
pp. 35
Author(s):  
Suparna Wijaya ◽  
Dewi Sekarsari Kusumaningtyas

Dealing with the practice of tax avoidance in general, many countries have compiled and implemented their own general anti-avoidance rules (GAAR). This research aims to explore the potential of statutory GAAR in handling tax avoidance practices in Indonesia and SAAR formulas that are suitable for the Indonesian context. This qualitative research employed a case study approach. Results show that the application of SAAR and the principle of substance over form in Indonesia cannot yet be applied properly; thus GAAR is needed. It is expected that the implementation of statutory GAAR can accommodate the limitations of regulators in light of unknown and future tax avoidance schemes.. Keywords: Tax-avoidance, tax planning, specific anti avoidance rule (SAAR), international tax


1996 ◽  
Vol 2 (8) ◽  
pp. 16-17
Author(s):  
D. R. Savvides

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