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Tax authorities in several countries have intensified their surveillance of intercompany transfer pricing in recent years. This paper examines the legislative and administrative issues related to the treatment of intercompany transfer pricing for tax purposes. It reviews the existing international guidelines and national rules on methods for determining appropriate transfer prices, as well as the issues related to tax administration practices for the implementation of those rules. Various systems, proposed or introduced to improve the predictability of taxation, are also examined. This paper further reviews the recent discussions on the “commensurate-with-income” standard and the pricing methodologies proposed thereunder. It finally reviews some alternative approaches to international income allocation which are proposed or adopted in lieu of the transfer pricing approach.
Macroeconomics --- Taxation --- International Taxation --- Taxation, Subsidies, and Revenue: General --- Personal Income, Wealth, and Their Distributions --- Tax Evasion and Avoidance --- Business Taxes and Subsidies --- Public finance & taxation --- Transfer pricing --- Double taxation --- Personal income --- Tax avoidance --- Transfer pricing rules --- Taxes --- National accounts --- Revenue administration --- Income --- Tax evasion --- United States
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Unilateral adoption of transfer pricing regulations may have a negative impact on real investment by multinational corporations (MNCs). This paper uses a quasi-experimental research design, exploiting unique panel data on domestic and multinational companies in 27 countries during 2006-2014, to find that MNC affiliates reduce their investment by over 11 percent following the introduction of transfer pricing regulations. There is no significant reduction in total investment by the MNC group, suggesting that these investments are most likely shifted to affiliates in other countries. The impact of transfer pricing regulations corresponds to an increase in the ``TPR-adjusted' corporate tax rate by almost one quarter.
Corporate Finance --- Taxation --- Corporate Taxation --- International Taxation --- Business Taxes and Subsidies --- International Fiscal Issues --- International Public Goods --- Multinational Firms --- International Business --- Taxation, Subsidies, and Revenue: General --- Public finance & taxation --- Multinationals --- Corporate & business tax --- Transnational corporations --- Transfer pricing rules --- Corporate income tax --- Transfer pricing --- Thin capitalization rules --- Economic sectors --- Taxes --- International business enterprises --- Corporations --- Double taxation --- Bosnia and Herzegovina
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A growing empirical literature has documented significant profit shifting activities by multinationals. This paper looks at the impact of such profit shifting on real activity and tax competition. Real activity can be affected as profit shifting changes—and theoretically most likely reduces—the cost of capital. Tax competition, even over real capital, is affected, because a permissive attitude toward profit shifting can be seen as a selective tax reduction for multinationals. Tightening profit shifting rules in turn can affect tax competition through the main rate. This paper discusses these issues theoretically and with the help of a simulation to assess the impact of profit-shifting on investment, revenues, and government behavior. Using the theoretical framework, it also provides a brief overview of the related empirical literature.
Public Finance --- Taxation --- Corporate Taxation --- Taxation, Subsidies, and Revenue: General --- Business Taxes and Subsidies --- Public finance & taxation --- Corporate & business tax --- Thin capitalization rules --- Transfer pricing rules --- Corporate income tax --- Anti-avoidance rules --- Revenue administration --- Taxes --- Double taxation --- Corporations --- Revenue --- United States
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A growing empirical literature has documented significant profit shifting activities by multinationals. This paper looks at the impact of such profit shifting on real activity and tax competition. Real activity can be affected as profit shifting changes—and theoretically most likely reduces—the cost of capital. Tax competition, even over real capital, is affected, because a permissive attitude toward profit shifting can be seen as a selective tax reduction for multinationals. Tightening profit shifting rules in turn can affect tax competition through the main rate. This paper discusses these issues theoretically and with the help of a simulation to assess the impact of profit-shifting on investment, revenues, and government behavior. Using the theoretical framework, it also provides a brief overview of the related empirical literature.
United States --- Public Finance --- Taxation --- Corporate Taxation --- Taxation, Subsidies, and Revenue: General --- Business Taxes and Subsidies --- Public finance & taxation --- Corporate & business tax --- Thin capitalization rules --- Transfer pricing rules --- Corporate income tax --- Anti-avoidance rules --- Revenue administration --- Taxes --- Double taxation --- Corporations --- Revenue
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Profit shifting remains a key concern in international tax system debate, but discussions are largely based on aggregate estimates, with less attention paid to individual sectors. Drawing on a novel dataset, we quantify tax avoidance risks in the extractive industries, a sector which is revenue critical for many developing economies. We find that a one percentage point increase in the domestic corporate tax rate has historically reduced sectoral profits by slightly over 3 percent; and the response tends to be more pronounced among mining than among hydrocarbon firms. There is only weak evidence transfer pricing rules contain tax minimization efforts of MNEs in our sample, but interest limitation rules (e.g., thin capitalization or earnings based rules) do reduce the observable extent of profit shifting. Our findings highlight the challenge of taxing income in the natural resource sector and suggest how fiscal regime design might be strengthened.
Agricultural and Natural Resource Economics --- Business Taxes and Subsidies --- Corporate & business tax --- Corporate income tax --- Corporate Taxation --- Corporations --- Environmental and Ecological Economics: General --- Environmental management --- Extractive industries --- Industry Studies: Primary Products and Construction: General --- Mineral industries --- Mining sector --- Natural Resource Extraction --- Natural Resources --- Natural resources --- Public finance & taxation --- Tax avoidance --- Tax Evasion and Avoidance --- Tax evasion --- Taxation --- Taxation, Subsidies, and Revenue: General --- Transfer pricing rules --- Azerbaijan, Republic of
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This handbook is one of the first of its kind to focus attention on effectively administering revenues from extractive industries. It provides policymakers and officials in developing and emerging market economies with practical guidelines to establish a robust legal framework, organization, and procedures for administering revenue from these industries. It discusses transparency and how to promote it in the face of increasing demands for clarity and how developing countries can strengthen their managerial and technical capacity to administer these revenues.
Natural resources --- Mineral industries --- Revenue --- Tax administration and procedure --- Taxation --- Accounting --- E-books --- Taxation. --- Duties --- Fee system (Taxation) --- Tax policy --- Tax reform --- Taxation, Incidence of --- Taxes --- Finance, Public --- Tax practice --- Tax procedure --- Government revenue --- Public revenue --- Extractive industries --- Extractive industry --- Metal industries --- Mines and mining --- Mining --- Mining industry --- Mining industry and finance --- Industries --- National resources --- Resources, Natural --- Resource-based communities --- Resource curse --- Economic aspects --- United States --- Public Finance --- International Taxation --- Natural Resource Extraction --- Natural Resources --- Agricultural and Natural Resource Economics --- Environmental and Ecological Economics: General --- Taxation, Subsidies, and Revenue: General --- Business Taxes and Subsidies --- Auditing --- Public Administration --- Public Sector Accounting and Audits --- Environmental management --- Public finance & taxation --- Management accounting & bookkeeping --- Taxation & duties law --- Natural resource taxes --- Revenue administration --- Tax administration core functions --- Transfer pricing rules --- Public finance accounting --- Environment --- Public financial management (PFM)
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