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This paper investigates how concealment costs of transfer pricing and the probability of detection affect transfer pricing and firm behavior. We find that transfer pricing in intermediate production factors does not affect real activity of a multinational firm if the firm's concealment effort as...
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This chapter provides a description of one of the key anti-tax-avoidance rules to combat profit shifting by multinational corporations, so called Controlled Foreign Corporation (CFC) rules that directly target income in low-tax countries. We explain some key institutional features of CFC...
Persistent link: https://www.econbiz.de/10014505306
Multinational companies can exploit the tax advantage of debt more aggressively than national companies. Besides utilizing the standard debt tax shield, multinationals can shift debt from affiliates in low-tax countries to affiliates in high-tax countries. We study the capital structure of...
Persistent link: https://www.econbiz.de/10010342883
This study develops theory and discusses implications of flexibility in income shifting for multinational corporations that have both profit- and loss-making affiliates. Our theoretical model shows that when multinationals do not have flexibility to adjust their income-shifting strategies within...
Persistent link: https://www.econbiz.de/10012893688
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This study examines the flexibility of multinational firms to adjust their income-shifting strategies -- whether using transfer pricing or internal debt -- during the tax year to react to affiliates' operating losses. We develop the concept that under flexibility, multinationals can adjust their...
Persistent link: https://www.econbiz.de/10012932797
There is a growing concern that governments lose substantial corporate tax revenue because of profit shifting through transfer-pricing and thin-capitalization strategies. Existing literature studies profit shifting and transfer pricing separately. In practice, the choice of debt-to-asset ratios...
Persistent link: https://www.econbiz.de/10013076733
We demonstrate that the choice of the transfer price and its effect on intra-firm trade and investment depends on the probability of detection and thus on the measure, on which tax authorities base their audit. A policy implication of the paper is that it should be preferable to condition audits...
Persistent link: https://www.econbiz.de/10013046061
The increasing use of intellectual property as a means to shift profits to low-tax jurisdictions or jurisdictions with so-called ‘patent boxes’ is a major challenge for the corporate tax base of medium- and high-tax countries. Extending a standard tax competition model for capital-enhancing...
Persistent link: https://www.econbiz.de/10012908675