scholarly journals Estimating an impact of base erosion and profit shifting (BEPS) countermeasures — a case of business group

2017 ◽  
Vol 8 (4) ◽  
pp. 621-642 ◽  
Author(s):  
Renata Legenzova ◽  
Kristina Levišauskaitė ◽  
Egidijus Kundelis
Keyword(s):  
Income Tax ◽  
Case Analysis ◽  
Business Group ◽  
Corporate Income Tax ◽  
Macro Level ◽  
Profit Shifting ◽  
Professional Literature ◽  
Micro Level ◽  
Transaction Level ◽  
Level Analysis

Research background: Base erosion and profit shifting (BEPS) is a reduction of corporate income tax base and related corporate income tax payments via taking advantage of tax loopholes. OECD prepared 15 BEPS actions, which set countermeasures to fight tax avoid-ance in a coordinated way and shall be implement by countries on a voluntary basis. Literature review revealed that on a macro-level and company-level the extent of BEPS is large and statistically significant while studies addressing micro-level (transaction-level) impact and BEPS countermeasures’ related issues are limited. Purpose of the article: to identify methods and metrics available for evaluation of BEPS countermeasures’ impact on a micro-level and to assess BEPS countermeasures’ impact on a business group. Methods: the paper employs comparative analysis of scientific and professional literature to identify approaches and methods available for evaluation of BEPS countermeasures’ impact on a micro-level; and a case analysis method to assess an expected impact of BEPS coun-termeasures on a specific business group.  Findings & Value added: An approach used to estimate BEPS countermeasures impact on the micro-level differs from the one applied in macro-level analysis. To conduct the case analysis, OECD’s proposed macro-level fiscal impact assessment approach has been adapted for a micro-level analysis. It includes the analysis of the transactions subject to BEPS countermeasures and develops an action plan to manage related risks. The conducted case analysis differs from previous research as it employs transaction-level data and estimates fiscal effect of BEPS countermeasures on a micro-level. Analysis of the activities of the specific business group revealed that 5 from 15 countermeasures are relevant and directly applicable to this business group. They would not have an immediate significant direct fiscal effect, but risks related to BEPS countermeasures exist and action plans to manage negative effects of BEPS countermeasures have to be implemented.

Current Language Maintenance Research in Jordan

2016 ◽  
Vol 8 (4) ◽  
pp. 218
Author(s):  
Abdelkader M. Alshboul
Keyword(s):  
Language Use ◽  
Language Maintenance ◽  
Sociodemographic Factors ◽  
Macro Level ◽  
Complex Picture ◽  
Language Maintenance And Shift ◽  
Micro Level ◽  
Level Analysis ◽  
The Way

<p>This paper investigates the methodology utilized in Jordanian language maintenance and shift research on six minorities including Chechens, Armenians, Gypsies, Druze, Circassian, and Kurds. It argues that the methodology has been based on the macro-level analysis that examined the role of a number of sociodemographic factors in the LMLS process. However, this analysis does not offer a complex picture of immigrants’ language use and attitudes. It is suggested in this paper that the micro level analysis should also be employed to illuminate the way language is negotiated and used. </p>

scholarly journals A Study from Slovakia on the Transfer of Slovak Companies to Tax Havens and Their Impact on the Sustainability of the Status of a Business Entity

2019 ◽  
Vol 11 (10) ◽  
pp. 2803
Author(s):  
Samer Khouri ◽  
Lubos Elexa ◽  
Michal Istok ◽  
Andrea Rosova
Keyword(s):  
Income Tax ◽  
Financial Statements ◽  
Tax Planning ◽  
Corporate Income Tax ◽  
Profit Shifting ◽  
Tax Havens ◽  
Tax Haven ◽  
Before And After ◽  
The Status ◽  
The One

The main aim of this paper is to provide empirical evidence about profit-shifting to selected tax havens by Slovak companies. This contribution focused on the very rare evidence of use of tax havens by Slovak companies not only in the field of corporate income tax, but also in selected areas of profitability. Two sources of data were used. Lists of Slovak companies with tax haven links were provided by the company, Bisnode, and financial statements of investigated companies were gained from the Finstat database. Based on the available data, the investigated period was between 2008 and 2016. We statistically tested selected indicators (ETR, taxes per assets, ROE, ROA, and ROS) of Slovak companies with direct ownership links to tax havens compared to their counterparts. Our findings suggest that Slovak companies with an ownership link to tax havens pay significantly lower taxes compared to companies without ownership links to tax havens during the period monitored. The aggressive tax planning was not only confirmed by the significantly lower reported values of ETR and taxes per assets, but also by the lower values of ROA. On the one side, Slovak companies with ownership links to midshore tax havens had the highest values of ROE, ROA, and ROS, but on the other side, these Slovak companies reported the highest ETR among the appointed categories (onshore, midshore, and offshore). The lowest taxes paid per unit of total assets were found in Slovak companies with ownership links to onshore tax havens. The analysis was supplemented by the changes of the selected indicators before and after obtaining an ownership link to a tax haven.

Korean EFL students’ argumentative writing in L1 and L2: A comparative move analysis study

2020 ◽  
Vol 19 (2) ◽  
pp. 217-230
Author(s):  
Soomin Jwa
Keyword(s):  
Macro Level ◽  
Contrastive Rhetoric ◽  
Content Type ◽  
English Writing ◽  
Korean And English ◽  
Efl Students ◽  
Micro Level ◽  
Thesis Statement ◽  
L1 And L2 ◽  
Level Analysis

Purpose This comparative study aims to investigate the rhetorical organization of Korean and English argumentative texts. In previous studies, the rhetorical organization of such texts has been categorized as either direct or indirect depending on the placement of the thesis statement (Chien, 2011). The present study attempts to document more specific rhetorical patterns using Swales (1990) concept of moves and steps. Design/methodology/approach Ten Korean EFL students with similar L1 and L2 literacy backgrounds were selected, and, adopting a within-subject design, the students wrote two argumentative essays, one in Korean and one in English, in response to two different topics. The students’ essays were analyzed at both the macro and micro levels. The focus of the macro-level analysis was on the placement of the thesis statement and of topic sentences in each of the body paragraphs. Once the macro-level analysis was done, the essays were analyzed at the micro level using Swales (1990) move analysis. Findings The findings suggest that both texts were organized in a similar way at the macro level, constituting a typical paper structure (i.e. introduction, body and conclusion). However, a difference appears at the micro level: the students used a variety of steps to create a move when writing in Korean, whereas little variation was found in the English texts. An analysis of the data suggests the possibility that the standardized moves and steps in the English texts may be due not to culture-specific rhetoric, but to a lack of practice with rhetorical thinking in English. Originality/value In previous studies, the rhetorical organization of texts has been categorized as either direct or indirect depending on the placement of the thesis statement. The present study uses the framework of move analysis to describe more specific organizational patterns of Korean and English writing to determine the extent to which Korean and English writing is similar in the genre of argumentative writing. Another significance of the study lies in the choice of Korean writing as a reference point for comparison with English writing. It has been widely noted that there is a dearth of research of Korean students’ writing in contrastive rhetoric. To the best of the author’s knowledge, most of the contrastive rhetoric studies were conducted with Chinese or Japanese student writers.

scholarly journals Religiousness and existential insecurity: A cross-national comparative analysis on the macro- and micro-level

2019 ◽  
Vol 34 (1) ◽  
pp. 19-37 ◽  
Author(s):  
Franz Höllinger ◽  
Johanna Muckenhuber
Keyword(s):  
Final Section ◽  
Macro Level ◽  
Individual Level ◽  
Life Conditions ◽  
Micro Level ◽  
Multi Level ◽  
Using Data ◽  
The Individual ◽  
Level Analysis ◽  
Cross National

In Sacred and Secular (2011 [2004]) Norris and Inglehart argued that improvements in material living conditions and higher degrees of existential security lead to a decline in religiousness both on the macro-level of the comparison between countries and on the individual level. Since then, a number of studies have examined this relationship and confirmed the assumptions of the existential security thesis. This article revisits this thesis using data from the sixth wave of the World Values Survey (2010–2014). The multi-level analysis reveals two key results. Consistent with previous studies, a strong correlation was found between better life conditions and lower levels of religiousness on the macro-level. Individual life conditions and threatening experiences, however, have only a very small impact on religiousness. Possible explanations for the discrepancy between macro-level and micro-level results are discussed in the final section.

Demographic change and its social and political implications in the Middle East

2016 ◽  
Vol 2 (1) ◽  
pp. 70-86 ◽  
Author(s):  
Shingo Hamanaka
Keyword(s):  
Middle East ◽  
Empirical Analysis ◽  
Demographic Change ◽  
Interactive Effect ◽  
Food Prices ◽  
Macro Level ◽  
Political Implications ◽  
Micro Level ◽  
Youth Bulge ◽  
Level Analysis

This study examines the effect of the demographic trend on the breakdown of authoritarian regimes in the Middle East. Several scholars have pointed out that the combination of youth’s disproportionate share of the total population, the “youth bulge,” and high unemployment throws a society into turmoil. The demographic change determines not only how human activities are conducted but also how a society embarks on a political transition, such as a revolution, a state breakdown, or a regime change. I conduct two levels of empirical analysis of the political implications of the demographic dynamics in the Middle East. First, the macro-level analysis is based on cross-sectional data over two decades. This analysis will clarify whether the youth population had a significant effect on the Arab uprisings. Second, the micro-level analysis uses survey data from the Arab Democracy Barometer wave III to examine whether there is a significant correlation between youth and participation in protest. This analytical approach integrates the macro level with the micro level in order to avoid an ecological inference. My empirical analysis finds evidence to support Jack Goldstone’s revolution theory: it is built on demographic changes accompanied by rising food prices. The hypothesis is tested by examining the interactive effect of youth bulge and the deteriorating economic situation in the two decades following the end of the Cold War. The empirical tests at both the macro and micro levels identify a statistically significant effect.

scholarly journals A Case Study On Financial Performance Of Centurion Bank And Bank Of Punjab-In Pre And Post Merger Period

1970 ◽  
Vol 3 (3) ◽  
pp. 210-221
Author(s):  
P. Chellasamy ◽  
J. Udhaya Kumar
Keyword(s):  
Private Sector ◽  
Financial Performance ◽  
Commercial Banks ◽  
Macro Level ◽  
Micro Level ◽  
One Year ◽  
Level Analysis ◽  
Rare Opportunity

Merger of commercial banks provide a very rare opportunity for examining whether the merger has been successful or not, most of the attempts would either concentrate on anticipated economics or they have been conducted on a macro level. Independent micro level analysis is, therefore, necessary to examine the various aspects of merger. Accordingly centurion bank- bank of Punjab merger has been opted for a case study. It has been intentionally selected as this deal has been the recent merger (i.e.) one year deal between two private sector banks.

scholarly journals Scheming and Re-scheming: Secondary Mathematics Teachers’ Use and Re-use of Resources

2021 ◽  
Author(s):  
Lina Kayali ◽  
Irene Biza
Keyword(s):  
Mathematics Teachers ◽  
Secondary Mathematics ◽  
Macro Level ◽  
Secondary Mathematics Teachers ◽  
Documentational Approach ◽  
Use Of Resources ◽  
Micro Level ◽  
Level Analysis ◽  
Operational Invariants

AbstractIn this article, we examine secondary mathematics teachers’ work with resources using the Documentational Approach to Didactics lens. Specifically, we look at the resources and a teacher’s scheme of use (aims, rules of actions, operational invariants, and inferences) of these resources across a set of lessons (macro-level analysis) that aim towards students’ preparation for the examinations and how this use emerges in a set of three lessons on the same topic (micro-level analysis) as a response to contingent moments. We propose the terms scheming—a teacher’s emerging scheme of use related to the same set of resources used for the same aim—and re-scheming, namely, shifts in such scheming. Our analysis of lesson observations and the teacher’s reflections on his actions from a post-observation interview demonstrate the interplay between the stable characteristics of the scheme of use and the scheming and re-scheming in individual lessons. We conclude this article with a discussion on the methodological potential of using both macro- and micro-level analyses in the investigation of teachers’ use of resources.

scholarly journals Problems and the future of corporate income tax and VAT in the conditions of digitalization

2021 ◽  
Vol 3 (95) ◽  
pp. 52-69
Author(s):  
Оksana Garkushenko ◽  
◽  
Olha Kuvaldina ◽  
Keyword(s):  
International Trade ◽  
Tax Evasion ◽  
Information Exchange ◽  
Income Tax ◽  
Cash Flows ◽  
Corporate Income Tax ◽  
Profit Shifting ◽  
Global Trends ◽  
Blockchain Technology ◽  
The Future

Globalization and digitalization lead to significant changes in society and economy, including the field of taxation. Moreover, the efforts of governments of many countries are aimed at implementing measures to combat profit shifting and ensure that budget revenues from corporate income tax and VAT are received in the proper amount. The article analyses main problems of corporate income tax and VAT, possible ways to solve them in near and distant perspectives. With regard to respective taxes, the main aspects of combating tax base erosion and tax evasion with the use of new digital methods, and the state of BEPS steps implementation in this part are analysed. Given that the corporate income tax in modern conditions has a number of disadvantages, it is likely that in the future it will be replaced by an alternative – a tax on withdrawn capital or a tax on cash flows at destination. VAT, in turn, is a neutral tax that is easy to algorithmize and administer. Therefore, it can also displace corporate income tax from the tax systems of countries. At the same time, there are a number of problems with VAT: cases of fraud, non-taxation or double taxation of transactions in international trade. It has been found that in the short run (up to 5 years) it is important for national governments to increase efforts to implement BEPS plan and to strengthen information exchange and international cooperation to counteract base erosion and profit shifting. To simplify VAT administration and improve the interaction between taxpayers and tax authorities within the same country, as well as in international trade, it is feasible to use the e-invoicing practice more widely. In distant perspective, it is possible to use blockchain technology. Taking into account global trends, the article provides recommendations for improving VAT and corporate income tax in the context of globalization and digitalization (in particular – further implementation of BEPS measures in all countries of the world, mandatory registration as VAT payers in jurisdictions, where sells of goods and services to end users take place, strengthening international coordination and cooperation in the field of taxation), as well as general recommendations that should contribute to digitalization and economic development of Ukraine in the near and distant future.

scholarly journals Corporate taxation in Denmark and the international challenge

2014 ◽  
Vol 2014 (2) ◽  
pp. 88-112
Author(s):  
Anna Holst ◽  
Anders Fuglsig Larsen
Keyword(s):  
Tax Competition ◽  
Income Tax ◽  
Corporate Income Tax ◽  
Tax Revenue ◽  
Complex Task ◽  
Profit Shifting ◽  
Tax Base ◽  
Policy Makers ◽  
International Tax Competition ◽  
Base Broadening

Abstract We study the development in the Danish corporate income tax base and the corporate income tax revenue in the period from 1990 until present. Measured in per cent of GDP the CIT base has out-paced the revenue due to parallel CIT rate cuts and base broadening reforms. We seek to explain the development in the CIT base and discuss whether this is threatened by base erosion and profit shifting. Describing the development in the CIT tax base is a comprehensive and complex task and to pin-point one single cause is not possible. But it is possible to point to elements which have contributed to the development. We conclude that there exists a challenge in terms of international tax competition but find no evidence of the Danish CIT base suffering from this. The challenge for policy makers is designing a tax system which on one side secures sufficient revenue and on the other hand is internationally competitive.

CONCEPTUAL NATURE OF THE CORPORATE INCOME TAX

2009 ◽  
Vol 36 (2) ◽  
pp. 31-74 ◽  
Author(s):  
Hugo Nurnberg
Keyword(s):  
Conceptual Framework ◽  
Income Tax ◽  
Corporate Income Tax ◽  
Extensive Discussion ◽  
Professional Literature ◽  
Accounting Standard ◽  
Financial Reports ◽  
Entity Theory ◽  
Income Statement ◽  
Conceptual Nature

This paper examines a long-standing controversy about the conceptual nature of the corporate income tax: whether it is an expense, a loss, a distribution of income, or some anomalous item. That controversy reflects in part different theories of the accounting entity. Despite several authoritative pronouncements stating or implying that the tax is an expense, and despite an extensive discussion in the academic and professional literature, the controversy has never been fully resolved. Additionally, the tax is not characterized as an expense in corporate financial reports. The FASB's conceptual framework does not resolve this controversy, nor does the impending joint FASB-IASB revised conceptual framework. Within the context of a coalesced (or fused) proprietary-entity theory of the accounting entity, this paper leads to the unsurprising conclusion that the corporate income tax is an expense, albeit an expense with some remarkable characteristics. Additionally, this paper shows how the conceptual nature of the corporate income tax impacts its income statement and cash flow statement reporting, and how a better understanding of this conceptual controversy might preclude fruitless controversies over other accounting issues currently troubling accountants and accounting standard setters.

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