This paper analyzes the role of Tax Incentives in promoting investment, their effectiveness and their revenue and other costs and political economy. The paper consolidates econometric work on the topic done by the authors covering the Caribbean, Francophone Africa and India; surveys of Investors...

A recent KPMG transfer pricing study posits fixed percentages for returns to marketing and distribution activities, a.k.a. Amounts B and C in OECD parlance. The study casts some light on the OECD's design for a new global tax allocation respecting the profits of certain digital economy firms. By...

In consonance with globalization, the International Transfer Pricing (ITP) rules have also been introduced in the countries, where they did not exist, or reformed as per the OECD guidelines in a number of countries where they already existed. In many countries the process of revamping these...

Transfer pricing rules in India, were introduced in 2001, however, there are issues of tedious documentation, complicated procedures, rigorous penalties. Therefore, this subject has emerged as biggest source of courtroom battles. Recently, system has been improved by incorporating APAs, SHRs,...

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...

Conducted in a framework which embodies tax-shifting opportunities, risk of losses and possibility of interjurisdictional loss-offset, this paper investigates a reform of multijurisdictional enterprises taxation, a move from Separate Accounting to Formulary Apportionment. Findings are summarised...

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...

Against a background of rather mixed evidence about transfer pricing practices in multinational enterprises (MNEs) and varying attitudes on the part of tax authorities, this paper explores how multiple aims in transfer pricing can be pursued across four different transfer pricing regimes. A MNE...

This paper examines the flexibility of multinational firms to use income-shifting strategies within a tax year to react to operating losses. First, we develop an analytical model that considers how affiliate losses can be adjusted by using the transfer prices of tangible and intangible assets,...