scholarly journals Debt Shifting and Transfer Pricing in a Volatile World

2020 ◽  
Author(s):  
Nicola Comincioli ◽  
Paolo Panteghini ◽  
Sergio Vergalli
Keyword(s):  
Transfer Pricing ◽  
Debt Shifting

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.

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 Profit Shifting and Industrial Heterogeneity

2019 ◽  
Vol 66 (2) ◽  
pp. 134-156 ◽  
Author(s):  
Salvador Barrios ◽  
Diego d'Andria
Keyword(s):  
Transfer Pricing ◽  
Indirect Evidence ◽  
Profit Shifting ◽  
Traditional Use ◽  
Developed Economies ◽  
Level Data ◽  
Sectoral Differences ◽  
Debt Shifting ◽  
Intangible Investment ◽  
Industrial Heterogeneity

Abstract Base erosion and profit shifting undermines tax revenues collection and raises public discontent in times when the tax burden has increased significantly for households in most developed economies. In addition, new forms of profit shifting related to intangible investment have emerged rapidly along the traditional use of transfer pricing and debt shifting by multinational companies. In this article, using worldwide company level data for the period 2004–2013, we demonstrate that the sectoral differences in profit shifting are a serious concern from a welfare and policy perspectives. Sectors performing more profit shifting lower their average cost of capital and are thus able to attract more investment to the detriment of sectors less able to dodge taxes. We develop a multilevel model and provide indirect evidence of the welfare costs caused by profit shifting by estimating the cross-sectoral variance of semi-elasticity of declared profit. We also demonstrate that having a larger share of intangible assets is not per se related to more profit shifting and that it may point instead to cross-sectoral differences. Finally, we detect almost no financial shifting and find that the largest part of profit shifting is done by means of transfer pricing.

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.

Thin Capitalization, Transfer Pricing Aggresiveness, Penghindaran Pajak

2018 ◽  
Vol 2 (1) ◽  
pp. 1-28
Author(s):  
Teza Deasvery Falbo ◽  
Amrie Firmansyah
Keyword(s):  
Regression Analysis ◽  
Linear Regression ◽  
Stock Exchange ◽  
Transfer Pricing ◽  
Linear Regression Analysis ◽  
Tax Avoidance ◽  
Total Sample ◽  
Multiple Linear Regression Analysis ◽  
Tax Revenue ◽  
Thin Capitalization

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.

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