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11 European countries now operate IP Box regimes that provide substantially reduced rates of corporate tax for income derived from important forms of intellectual property. We incorporate these policies into forward-looking measures of the cost of capital, effective marginal tax rates and...
Persistent link: https://www.econbiz.de/10010957709
We present a new model of tax induced transfer pricing as an alternative to the oft-used concealment model. Inspired by interviews with practitioners, we consider a large multinational firm which is audited by the tax authority in the high-tax location. When this country adjusts the transfer...
Persistent link: https://www.econbiz.de/10010877753
The predominant model of tax induced transfer pricing is based on the assumption that profit shifting is due to insufficient enforcement. However, evidence shows that the firms responsible for most profit shifting are also among the most frequently audited. We present an alternative model based...
Persistent link: https://www.econbiz.de/10011440003
11 European countries now operate IP Box regimes that provide substantially reduced rates of corporate tax for income derived from important forms of intellectual property. We incorporate these policies into forward-looking measures of the cost of capital, effective marginal tax rates and...
Persistent link: https://www.econbiz.de/10010328037
11 European countries now operate IP Box regimes that provide substantially reduced rates of corporate tax for income derived from important forms of intellectual property. We incorporate these policies into forward-looking measures of the cost of capital, effective marginal tax rates and...
Persistent link: https://www.econbiz.de/10010322342
We present a new model of tax induced transfer pricing as an alternative to the oft-used concealment model. Inspired by interviews with practitioners, we consider a large multinational firm which is audited by the tax authority in the high-tax location. When this country adjusts the transfer...
Persistent link: https://www.econbiz.de/10010398549
Tax planning with intangibles has become one of the most popular and most vividly debated topics in international taxation. We incorporate various intellectual property (IP) tax planning models into forward-looking measures of effective tax rates, namely the disposal of intangibles to low-tax...
Persistent link: https://www.econbiz.de/10010457067
We present a new model of tax induced transfer pricing as an alternative to the oft-used concealment model. Inspired by interviews with practitioners, we consider a large multinational firm which is audited by the tax authority in the high-tax location. When this country adjusts the transfer...
Persistent link: https://www.econbiz.de/10010507653
The study analyses the incentives for multinationals caused by linking different national tax systems. The dividend tax capitalization hypothesis is extended to include taxes during the repatriation and onward distribution (as equalization tax) to derive the relevant cost of capital formulae for...
Persistent link: https://www.econbiz.de/10011509386
This paper explores the impacts of adopting two corporate income tax reforms simultaneously: the conversion to a cash-flow tax, that would allow the expensing of investment while disallowing interest deductions, and the switch to sales-based formula apportionment, that would tax worldwide...
Persistent link: https://www.econbiz.de/10012987898