It is usually a straightforward tax question: is an advance of capital to a business debt or equity? But in some cases the question gets harder to answer, mostly because of the tangled multi-factor test we use. Long ago most tax practitioners gave up trying to clean up the process of answering...

Literature provides evidence of profit shifting of MNEs, particularly by intercompany debt. Therefore, we conducted a broad empirical investigation (survey), focusing on specific issues regarding cross-border intra-group financial transactions. This paper aims to work out empirical evidence of...

The paper provides estimates of the long-run, tax-adjusted, user cost elasticity of capital (UCE) in a small open economy, exploiting three sources of variation in Canadian tax policy: across provinces, industries, and years. Estimates of the UCE with Canadian data are less prone to the...

Tax treaties are often viewed as a mechanism for eliminating tax competition, however this approach ignores the need for bargaining over the treaty's terms. This paper focuses on how bargaining can affect the withholding taxes set under the treaty. In a simple framework, we develop hypotheses...

We investigate the outcome of bilateral tax competition by analyzing Double Tax Treaties (DTT). DTTs are the crucial means of splitting a tax base between two countries. Yet, there are only few empirical results on the textual design of DTTs. We develop a novel approach to quantitatively analyze...

Transfer Pricing policies are the focus of many investigations on corporate income around the world, yet corporations rarely use models and metrics to estimate their exposure to tax risk. In this paper I propose a framework for multinational enterprises to deal with transfer pricing risk, i.e....

This paper contributes to the empirical literature on the transfer pricing behavior of multinational firms. Previous research mainly focuses on transfer pricing as a means of tax optimization. Our approach concentrates on transfer pricing as a critical compliance issue. Specifically, we...

This paper investigates whether transfer pricing of intrafirm sales within multinationals represents an important channel of company tax planning. A simple theoretical model, considering profit shifting activities of a multinational company, is used to obtain empirical implications. The...

In recent years, a growing number of countries have enacted tax rules that require multinational enterprises (MNEs) to document their intra-firm trade prices and show that they are set as in third-party trade. The objective of these rules is to limit opportunities for strategic trade mis-pricing...

We provide indirect empirical evidence of profit shifting behavior by multinational enterprises. This issue is analyzed in an econometric panel study for the years 1995 to 2005 and additionally in a cross-section for 2004 using a large micro database of European subsidiaries of multinationals...