scholarly journals Debt Shifting and Thin-Capitalization Rules – German Experience and Alternative Approaches

2015 ◽  
Vol 2015 (1) ◽  
pp. 17-33 ◽  
Author(s):  
Martin Ruf ◽  
Dirk Schindler
Keyword(s):  
Empirical Studies ◽  
Theoretical Models ◽  
Economic Effects ◽  
Tax Reforms ◽  
Arm’S Length Principle ◽  
Debt Shifting ◽  
Alternative Approaches ◽  
German Data ◽  
Thin Capitalization ◽  
Promising Avenue

Abstract This paper presents the general design of thin-capitalization rules and summarizes the economic effects of such rules as identified in theoretical models. We review empirical studies providing evidence on the experience with (German) thin-capitalization rules as well as on the adjustment of German multinationals to foreign thin-capitalization rules. Special emphasis is given to the development in Germany, because Germany went a long way in limiting interest deductibility by enacting a drastic change in its thin-capitalization rules in 2008, and because superb German data on multinational finance allows for testing several aspects consistently. We then discuss the experience of the Nordic countries with thin-capitalization rules. Briefly reviewing potential alternatives as well, we believe that the arm’s-length principle is administratively too costly and impracticable, whereas we argue that controlled-foreign-company rules might be another promising avenue for limiting internal debt shifting. Fundamental tax reforms towards a system with either "allowance for corporate equity" (ACE) or a "comprehensive business income tax" (CBIT) should also eliminate any thin-capitalization incentive.

Economic Effects of 2004-2009 Tax Reforms: Retrospective Analysis

2012 ◽  
pp. 108-123
Author(s):  
E. Penukhina ◽  
D. Belousov ◽  
K. Mikhailenko
Keyword(s):  
Retrospective Analysis ◽  
Tax Policy ◽  
Economic Effects ◽  
Tax Policies ◽  
Policy Changes ◽  
Tax Reforms ◽  
Russian Economy ◽  
Balanced Budget ◽  
Budget System

The article determines, describes and analyzes phases of tax reforms in Russia. We estimate macroeconomic and fiscal effects of various tax policies held during the second and third phases of tax reforms. The necessity of providing a balanced budget system, as well as complex assessment of effects of tax policy changes for the development of the Russian economy is noted.

Emerging Syndromes

2017 ◽  
Author(s):  
Kelly C. Allison ◽  
Jennifer D. Lundgren
Keyword(s):  
Empirical Studies ◽  
Theoretical Models ◽  
Future Research ◽  
Night Eating Syndrome ◽  
Statistical Manual ◽  
Night Eating ◽  
Diagnostic And Statistical Manual ◽  
Impairment In Functioning ◽  
Atypical Anorexia Nervosa ◽  
Comorbid Psychopathology

The Diagnostic and Statistical Manual, fifth edition, of the American Psychiatric Association (2013) has designated several disorders under the diagnosis of otherwise specified feeding and eating disorder (OSFED). This chapter evaluates three of these, night eating syndrome (NES), purging disorder (PD), and atypical anorexia nervosa (atypical AN). It also reviews orthorexia nervosa, which has been discussed in the clinical realm as well as the popular press. The history and definition for each is reviewed, relevant theoretical models are presented and compared, and evidence for the usefulness of the models is described. Empirical studies examining the disorders’ independence from other disorders, comorbid psychopathology, and, when available, medical comorbidities, are discussed. Distress and impairment in functioning seem comparable between at least three of these emerging disorders and threshold eating disorders. Finally, remaining questions for future research are summarized.

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.

Confronting a Mercantile Elite: Bourbon Reformers and the Merchants of Lima, 1765–1796

2004 ◽  
Vol 60 (04) ◽  
pp. 519-558
Author(s):  
Patricia H. Marks
Keyword(s):  
South America ◽  
Pacific Coast ◽  
Point Of View ◽  
Economic Effects ◽  
Port City ◽  
Tax Reforms ◽  
Positive Effects ◽  
Colonial Peru ◽  
The Pacific ◽  
Significant Change

After Spain’s defeat in the Seven Years’ War (1757-1763), when the British had occupied Havana and Manila, a series of territorial, commercial, and tax reforms brought significant change to the viceroyalty of Peru. Their economic effects have been matters for debate ever since. Some historians have emphasized their positive effects. Following promulgation of the Reglamento de comercio libre of 1778, the volume and value of European manufactures exported to the Pacific coast of Spanish South America increased. Lima and its port city, Callao, remained important as commercial centers of Spanish South America. But others suggest that the viceregal capital—home to a powerful mercantile elite, the magnates of the consulado (merchant guild) of Lima—suffered a decline in its economic fortunes, as did the entire viceroyalty. Support for this point of view was widespread in late colonial Peru. In spite of the evidence for growth, a rising chorus of complaint bemoaned the increasing poverty of the viceroyalty in general and Lima in particular. How can we account for this discrepancy?

scholarly journals A Systematic Review on Attachment and Sleep at Preschool Age

Children ◽  
2021 ◽  
Vol 8 (10) ◽  
pp. 895
Author(s):  
Catarina Perpétuo ◽  
Eva Diniz ◽  
Manuela Veríssimo
Keyword(s):  
Systematic Review ◽  
Attachment Security ◽  
Biological Process ◽  
Sleep Problems ◽  
Empirical Studies ◽  
Theoretical Models ◽  
Preschool Age ◽  
Future Research ◽  
Parent Child Relationships ◽  
Present Systematic Review

Sleep is a biological process that impacts nearly every domain of a child’s life. Sleep-wake regulation influences and it is highly influenced by developmental variables related to parent-child relationships, such as attachment. The main goal of the present systematic review is to analyze and integrate the findings of empirical studies investigating the relations between attachment and sleep in preschool age, a period marked by important developmental changes that challenge both attachment system and sleep-wake regulation. A database search was performed using a combination of relevant keywords, leading to the identification of 524 articles, with 19 manuscripts assessed for eligibility; finally, seven studies (2344 children) were included. Overall, the findings were not consistent, with some studies reporting significant associations between attachment security and sleep quality, as well as between attachment insecurity and sleep problems, whereas others did not find significant associations. The results are discussed in light of the available theoretical models and integrated in the context of measurement approaches to attachment and sleep heterogeneity, aiming to guide future research on the topic.

Research on capital structure determinants: a review and future directions

2017 ◽  
Vol 13 (2) ◽  
pp. 106-132 ◽  
Author(s):  
Satish Kumar ◽  
Sisira Colombage ◽  
Purnima Rao
Keyword(s):  
Capital Structure ◽  
Meta Analysis ◽  
Empirical Studies ◽  
Secondary Data ◽  
Theoretical Models ◽  
Order Theory ◽  
Organizational Level ◽  
Future Research ◽  
Content Type ◽  
The Impact

Purpose The purpose of this paper is to study the status of studies on capital structure determinants in the past 40 years. This paper highlights the major gaps in the literature on determinants of capital structure and also aims to raise specific questions for future research. Design/methodology/approach The prominence of research is assessed by studying the year of publication and region, level of economic development, firm size, data collection methods, data analysis techniques and theoretical models of capital structure from the selected papers. The review is based on 167 papers published from 1972 to 2013 in various peer-reviewed journals. The relationship of determinants of capital structure is analyzed with the help of meta-analysis. Findings Major findings show an increase of interest in research on determinants of capital structure of the firms located in emerging markets. However, it is observed that these regions are still under-examined which provides more scope for research both empirical and survey-based studies. Majority of research studies are conducted on large-sized firms by using secondary data and regression-based models for the analysis, whereas studies on small-sized firms are very meager. As majority of the research papers are written only at the organizational level, the impact of leverage on various industries is yet to be examined. The review highlights the major determinants of capital structure and their relationship with leverage. It also reveals the dominance of pecking order theory in explaining capital structure of firms theoretically as well as statistically. Originality/value The paper covers a considerable period of time (1972-2013). Among very few review papers on capital structure research, to the best of authors’ knowledge; this is the first review to identify what is missing in the literature on the determinants of capital structure while offering recommendations for future studies. It also synthesize the findings of empirical studies on determinants of capital structure statistically.

The virtue of narrowing: the fiscal federalism setting

2019 ◽  
pp. 99-128
Author(s):  
Pierre Salmon
Keyword(s):  
Theoretical Analysis ◽  
Fiscal Federalism ◽  
Empirical Studies ◽  
Empirical Work ◽  
Data Sets ◽  
Exact Nature ◽  
Yardstick Competition ◽  
Alternative Approaches ◽  
Short Section

This chapter mainly discusses the empirical work in the domain of local (subcentral) finance involving yardstick competition. It begins with a short section on the systemic novelty introduced by yardstick competition into the theory of fiscal federalism. The central part of the chapter focuses on the empirical arguments developed to probe the presence of yardstick competition and yardstick voting in various data sets. Then, some queries are formulated about the exact nature of what has been established empirically so far. It seems clearly confirmed that some form of yardstick competition or yardstick voting is at work in different settings. That result is important but the findings should not be supposed to validate the game-theoretical analysis or the pure mimicking behavior assumption typically associated with the empirical studies. Alternative approaches are considered toward the end of the chapter.

Challenges of Monitoring Tax Compliance by Multinational Firms: Evidence from Chile

2019 ◽  
Vol 109 ◽  
pp. 500-505
Author(s):  
Sebastián Bustos ◽  
Dina Pomeranz ◽  
José Vila-Belda ◽  
Gabriel Zucman
Keyword(s):  
Multinational Firms ◽  
Transfer Pricing ◽  
Tax Avoidance ◽  
Tax Compliance ◽  
Tax Rates ◽  
Profit Shifting ◽  
Effective Tax Rates ◽  
Arm’S Length Principle ◽  
Debt Shifting

This paper reviews common challenges of taxing multinational firms, using Chile as a case study. We briefly describe key international tax avoidance methods: profit shifting to low-tax jurisdictions through transfer pricing and debt shifting. We discuss the prevalent policy to tax multinationals--the arm's length principle--and alternative proposals using apportionment formulas. Novel data from Chile show that multinationals make up a large share of GDP but report lower profit and effective tax rates than local firms. In 2011, Chile implemented a reform following OECD guidelines to enforce the arm's length principle. We discuss potential effects on tax collection and welfare.

scholarly journals The Race to the Bottom Revisited: International Labour Law, Global Trade and Evolutionary Game Theory

2019 ◽  
Vol 40 (1) ◽  
pp. 53-81
Author(s):  
Maayan Menashe
Keyword(s):  
Game Theory ◽  
International Trade ◽  
Evolutionary Game ◽  
Theoretical Models ◽  
Economic Effects ◽  
Freedom Of Association ◽  
Labour Law ◽  
Race To The Bottom ◽  
Trade Law ◽  
International Trade Law

Abstract This article revisits the ‘race to the bottom’ in international labour law, in light of new developments in evolutionary and epistemic game theory and considering new empirical findings on the economic effects of labour rights. Accordingly, it explores two solutions to this collective action problem not previously analysed in labour law literature—‘indeterminate play’ and the ‘correlating device’—and it shows how these solutions relate to international trade law and international labour law. Moreover, a new perspective is offered, according to which international labour law and international trade law can be complementary in fostering global co-operation on labour regulation and in supporting development efforts. Through a novel characterisation of global labour governance according to three game theoretical models, this study ultimately highlights the importance of freedom of association and collective bargaining in enhancing co-operation among states and promoting processes by which countries’ social and economic development can be incrementally raised.

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