The Impact of Tax and Transfer Pricing on a Multinational Firm's Strategic Decision of Selling to a Rival

2019 ◽  
Vol 28 (9) ◽  
pp. 2279-2290 ◽  
Author(s):  
Vernon N. Hsu ◽  
Wenqiang Xiao ◽  
Jiayan Xu
Keyword(s):  
Transfer Pricing ◽  
Strategic Decision ◽  
The Impact

TRANSFER FİYATLAMA UYGULAMASININ İŞLETME PERFORMANSINA ETKİSİ VE VERGİSEL AÇIDAN DEĞERLENDİRİLMESİ

2014 ◽  
Vol 1 (2) ◽  
pp. 187
Author(s):  
Serdar KUZU
Keyword(s):  
Business Performance ◽  
Transfer Pricing ◽  
Tax Law ◽  
Economic Activities ◽  
Tax System ◽  
Goods And Services ◽  
Tax Legislation ◽  
International Transactions ◽  
The Cost ◽  
The Impact

The size of international trade continues to extend rapidly from day to day as a result of the globalization process. This situation causes an increase in the economic activities of businesses in the trading area. One of the main objectives of the cost system applied in businesses is to be able to monitor the competitors and the changes that can be occured as a result of the developments in the sector. Thus, making cost accounting that is proper according to IAS / IFRS and tax legislation has become one of the strategic targets of the companies in most countries. In this respect, businesses should form their cost and pricing systems according to new regulations. Transfer pricing practice is usefull in setting the most proper price for goods that are subject to the transaction, in evaluating the performance of the responsibility centers of business, and in determining if the inter-departmental pricing system is consistent with targets of the business. The taxing powers of different countries and also the taxing powers of different institutions in a country did not overlap. Because of this reason, bringing new regulations to the tax system has become essential. The transfer pricing practice that has been incorporated into the Turkish Tax System is one of the these regulations. The transfer pricing practice which includes national and international transactions has been included in the Corporate Tax Law and Income Tax Law. The aim of this study is to analyse the impact of goods and services transfer that will occur between departments of businesses on the responsibility center and business performance, and also the impact of transfer pricing practice on the business performance on the basis of tax-related matters. As a result of the study, it can be said that transfer pricing practice has an impact on business performance in terms of both price and tax-related matters.

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.

Understanding how the contextual variables influence political behaviour in strategic decision-making

2014 ◽  
Vol 7 (3) ◽  
pp. 226-250 ◽  
Author(s):  
Said Elbanna ◽  
Ioannis C. Thanos ◽  
Vassilis M. Papadakis
Keyword(s):  
Decision Making ◽  
Strategic Decision ◽  
Strategic Decision Making ◽  
Strategic Decisions ◽  
Empirical Examination ◽  
Content Type ◽  
Political Behaviour ◽  
Practitioner Education ◽  
The Impact ◽  
Practical Implications

Purpose – The purpose of this paper is to enhance the knowledge of the antecedents of political behaviour. Whereas political behaviour in strategic decision-making (SDM) has received sustained interest in the literature, empirical examination of its antecedents has been meagre. Design/methodology/approach – The authors conducted a constructive replication to examine the impact of three layers of context, namely, decision, firm and environment, on political behaviour. In Study 1, Greece, we gathered data on 143 strategic decisions, while in Study 2, Egypt, we collected data on 169 strategic decisions. Findings – The evidence suggests that both decision-specific and firm factors act as antecedents to political behaviour, while environmental factors do not. Practical implications – The findings support enhanced practitioner education regarding political behaviour and provide practitioners with a place from which to start by identifying the factors which might influence the occurrence of political behaviour in SDM. Originality/value – The paper fills important gaps in the existing research on the influence of context on political behaviour and delineates interesting areas for further research.

scholarly journals Optimising pasture and grazing management decisions on the Cicerone Project farmlets over variable time horizons

2013 ◽  
Vol 53 (8) ◽  
pp. 796 ◽  
Author(s):  
Karl Behrendt ◽  
Oscar Cacho ◽  
James M. Scott ◽  
Randall Jones
Keyword(s):  
Simulation Model ◽  
Strategic Decision ◽  
Stochastic Dynamic ◽  
Economic Returns ◽  
Strategic Decisions ◽  
Trade Offs ◽  
Using Data ◽  
Time Frames ◽  
The Impact ◽  
Stocking Rates

This study addresses the problem of balancing the trade-offs between the need for animal production, profit, and the goal of achieving persistence of desirable species within grazing systems. The bioeconomic framework applied in this study takes into account the impact of climate risk and the management of pastures and grazing rules on the botanical composition of the pasture resource, a factor that impacts on livestock production and economic returns over time. The framework establishes the links between inputs, the state of the pasture resource and outputs, to identify optimal pasture development strategies. The analysis is based on the application of a dynamic pasture resource development simulation model within a seasonal stochastic dynamic programming framework. This enables the derivation of optimum decisions within complex grazing enterprises, over both short-term tactical (such as grazing rest) and long-term strategic (such as pasture renovation) time frames and under climatic uncertainty. The simulation model is parameterised using data and systems from the Cicerone Project farmlet experiment. Results indicate that the strategic decision of pasture renovation should only be considered when pastures are in a severely degraded state, whereas the tactical use of grazing rest or low stocking rates should be considered as the most profitable means of maintaining adequate proportions of desirable species within a pasture sward. The optimal stocking rates identified reflected a pattern which may best be described as a seasonal saving and consumption cycle. The optimal tactical and strategic decisions at different pasture states, based on biomass and species composition, varies both between seasons and in response to the imposed soil fertility regime. Implications of these findings at the whole-farm level are discussed in the context of the Cicerone Project farmlets.

Mimoprávní vlivy na rozhodování českého Ústavního soudu

2021 ◽  
Author(s):  
Hubert Smekal ◽  
Jaroslav Benák ◽  
Monika Hanych ◽  
Ladislav Vyhnánek ◽  
Štěpán Janků
Keyword(s):  
Decision Making ◽  
Public Opinion ◽  
Strategic Decision ◽  
Strategic Decision Making ◽  
Constitutional Court ◽  
Judicial Decision ◽  
Judicial Decision Making ◽  
The Media ◽  
Book Studies ◽  
The Impact

The book studies other than purely legal factors that influence the Czech Constitutional Court judges in their decision-making. The publication is inspired by foreign models of judicial decision-making and discusses their applicability in the Czech environment. More specifically, it focuses, for example, on the influence of the judge’s personality, collegiality, strategic decision-making or the impact of public opinion and the media. The book is based mainly on interviews with current constitutional judges.

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 Remedies to Illicit Financial Flows from Transfer Pricing of Services and Hosting Intellectual Property in Kenya

2017 ◽  
Vol 3 (1) ◽  
pp. 113-130
Author(s):  
Charles Gordema
Keyword(s):  
Transfer Pricing ◽  
Primary Concern ◽  
Financial Flows ◽  
Taxable Income ◽  
Global Corporation ◽  
Intellectual Assets ◽  
Global Corporations ◽  
Illicit Financial Flows ◽  
The Impact ◽  
Pricing Of Services

Numerous reports in the last decade have focused on the challenges to African economies that emanate from the illicit transfers of funds and other valuable assets within some global corporations. A primary concern is the impact of these transfers on the taxable income of African subsidiaries. Two broad categories of intra-group transfers are of particular interest, partly because of the complexities they raise. One comprises transfers in payment of services exchanged among associated enterprises, while the other pertains to transfers by subsidiaries in payment of the value of intellectual assets attributed to the corporate centre of the global corporation. This article highlights the challenges raised by these transfers through case studies. It examines possible mechanisms to mitigate the challenges, drawing attention to current and impending developments. It concludes that there are good prospects for curbing illicit transfers linked to the examined types of transactions.

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