Nach § 147 Abs. 6 AO (Abgabenordnung) haben die Finanzbehörden "im Rahmen einer Außenprüfung das Recht, Einsicht in die gespeicherten Daten zu nehmen (...)". Hiervon betroffen sind Betriebs-, Umsatzsteuersonder-, Lohnsteueraußen- und Kapitalertragssteuerprüfungen sowie die...

IT-Compliance bezeichnet einen Zustand, in dem alle, die IT des Unternehmens betreffenden und verbindlich vorgegebenen bzw. als verbindlich akzeptierten Vorgaben nachweislich eingehalten werden. Sofern die Vorgaben aus Gesetzen stammen, bedeutet dies, dass sich Unternehmen an geltendes Recht zu...

We empirically analyze the determinants of regulatory costs associated with accounting, audit and tax rules in the European Union. Regulatory costs include transfer payments from losers to beneficiaries of such legislation. Hence, building upon a novel dataset, we estimate regulatory costs as...

Much has been said and written about the ‘fiscal behaviour' of multinationals. A tax code of conduct is often mentioned as a 'catch-all solution' for stimulating 'acceptable fiscal behaviour'. Stakeholders increasingly demand fiscal accountability to obtain verifiable and validated credible...

The international tax system developed as a form of technocratic governance, aimed at facilitating international investment, neglecting provisions for cooperation between national governments for tax enforcement. Its endogenous flaws resulted in its politicization in the 1970s, and again in the...

Successful IRS enforcement of corporate transfer pricing regulations is by all measures at an all-time low, and profit shifting from transfer pricing appears to be near an all-time high, costing the U.S. federal and state treasuries as much $140 billion dollars or more per annum in recent years,...

There are increasing policy concerns that aggressive international tax avoidance and offshore tax evasion significantly reduce government revenues. In particular, for some low income countries the amount of capital flight (where elites move and hide monies offshore in tax havens) exceeds foreign...

This paper studies how mandating higher book-tax conformity influences a manager's strategy to misreport financial and taxable incomes in the presence of a financial auditor and subsequently a tax auditor. The main result is that allowing for some differences between GAAP and tax laws minimizes...

Finding common ground between corporate tax compliance and enforcement appears difficult and expensive, judging by the current inventory of almost $200 billion in proposed IRS transfer pricing tax adjustments, and projections of as much as $100 billion or more in annual U.S. federal corporate...

Advance pricing agreements are long-term contracts between multinational taxpayers and tax authority(ies), according to which the taxpayer consents to use the agreed upon transfer price for its related transactions for a fixed period of time. We argue that for such an agreement to be based on...