Can formula apportionment really prevent multinational enterprises from profit shifting? The role of asset valuation, intragroup debt, and leases

Kiesewetter, Dirk; Steigenberger, Tobias; Stier, Matthias

doi:10.1007/s11573-018-0891-y

Cited by 6 publications

(2 citation statements)

References 32 publications

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“…Much scientific work deals with the formular apportionment of a CCCTB (Jakimovski 2012, p. 29). Furthermore, the formula itself is widely discussed (Kiesewetter, Steigenberger & Stier, 2018, p. 1032. The following articles deal with the formula factors and possible formula designs in a conceptual manner: Kahle (2007) analyses the apportionment based on factors of production, such as labour, capital and sales, and macroeconomic variables critically.…”

Section: Literature Overviewmentioning

confidence: 99%

Splitting of Corporate Taxes in Germany and Formulaic Distribution of a CCCTB – Critical Comparison

Müller-Thomczik

Reiter

2022

Central European Economic Journal

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The introduction of a formulaically apportioned common consolidated corporate tax base (CCCTB) could represent a milestone in international taxation. No agreement has yet been reached, however. In contrast, Germany already has a long-standing system that apportions corporate taxes by splitting trade tax and corporate income tax. This conceptual study, presented at the European Accounting Association (EAA) Congress in Bergen in 2022, will examine whether the German method of splitting could lead to some lessons for an appropriate design for an international profit distribution formula. Methodologically, we use a two-step approach: First, we compare the designs, and then we juxtapose both on a factual level. Next, we ask what the objectives these mechanisms have; do they even coincide? If the goals are not comparable, one cannot indisputably serve as a model for the other. We determine that, even though there are partial deviations, a closer look reveals significant overlaps; however, the German implementation is far from consistent and prioritises practicability. This leads us to our main result: The German system makes a clear value decision towards practicability, although there is a different set of aims. For the implementation of formulaic EU profit sharing, the lesson to be learned is that practicability should play a central role in the design of the formula. This lesson is important and helpful to accompany and support the implementation process in the EU.

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Section: Literature Overviewmentioning

confidence: 99%

Splitting of Corporate Taxes in Germany and Formulaic Distribution of a CCCTB – Critical Comparison

Müller-Thomczik

Reiter

2022

Central European Economic Journal

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“…Semakin tinggi transaksi afiliasi maka semakin besar penghindaran pajak yang dilakukan perusahaan (Sari et al 2017). Perusahaan multinasional menurunkan beban pajak melalui transfer pricing (Kiesewetter et al 2018). Transfer pricing dapat diterapkan dengan berbagai jenis transaksi afiliasi yaitu transaksi penjualan aset berwujud atau aset tidak berwujud, transaksi pemanfaatan aset tidak berwujud, transaksi jasa, dan transaksi biaya pinjaman (Permen, 2020).…”

Section: Transaksi Afiliasiunclassified

Skema Transfer Pricing Untuk Pengalihan Laba

Bakhram¹,

Siregar²,

Santoso³

2021

jabm

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More than 60% of world transactions used a transfer pricing scheme. Transfer pricing for tax avoidance is not in accordance with domestic Indonesian tax rules. This study aim to generate understanding about transfer pricing concept, determine transfer pricing risk factors, identify transfer pricing schemes, and explain transfer pricing risk management. Descriptive analysis method based on secondary data and literature studies applied in this research. This research shows that transfer pricing should be based on the arm's length principle. Factors that determine transfer pricing risks are inter-company transactions, tax rates, and foreign ownership. Transfer pricing can be implemented in intercompany transactions schemes related to sales, intangible asset, loan and services through one or a combination of several types of inter-company transactions. Transfer pricing risk management can be carried out through law enforcement, access of information agreement, and development of a transfer pricing risk-based monitoring system. The Directorate General of Taxes needs to pay attention to taxpayers who have affiliated transactions, lower tax rates, and foreign ownership in monitoring the risk of transfer pricing. Business groups also need to to fulfill the arm's length principle in the transfer pricing scheme in order to comply with the regulation.

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Is analytical tax research alive and kicking? Insights from 2000 until 2022

Niemann

Sailer

2023

J Bus Econ

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This literature review evaluates the development and impact of analytical tax research (ATR) from 2000 until 2022. Based on 345 research papers, we (1) identify emerging and declining research topics in the area of ATR, (2) examine the trends in publication outlets and author teams, and (3) analyze citation metrics at both the level of articles and authors to measure perception and impact of ATR. First, we find that rather new topics, such as the impact of taxation on entrepreneurship, innovation and R&D, have begun to attract attention. Second, tax journals are not the preferred outlet for ATR and author teams exhibit a decreasing gender imbalance. Third, citation metrics are highly centered on specific publications and individual authors. Moreover, publications that appeared in economics and finance journals generate disproportionately large citation numbers compared to those that were published in tax, accounting and business research journals. Authors from Anglo-American institutions have significantly more citations than researchers from German-speaking countries. We find that ATR does not form a closed community. It unites researchers from different backgrounds based on their— sometimes nonrecurring—thematic interest in the effects of taxation on economic decisions.

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Can formula apportionment really prevent multinational enterprises from profit shifting? The role of asset valuation, intragroup debt, and leases

Cited by 6 publications

References 32 publications

Splitting of Corporate Taxes in Germany and Formulaic Distribution of a CCCTB – Critical Comparison

Splitting of Corporate Taxes in Germany and Formulaic Distribution of a CCCTB – Critical Comparison

Skema Transfer Pricing Untuk Pengalihan Laba

Is analytical tax research alive and kicking? Insights from 2000 until 2022

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