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  • 1
    Language: English
    Pages: 1 Online-Ressource (circa 64 Seiten) , Illustrationen
    Series Statement: OECD Economics Department working papers no. 1355
    Keywords: Multinationales Unternehmen ; Unternehmensbesteuerung ; Steuerplanung ; Steuerrecht ; OECD-Staaten ; G20-Staaten ; Taxation ; Economics ; Amtsdruckschrift ; Arbeitspapier ; Graue Literatur
    Abstract: This paper exploits firm-level data from the ORBIS database to assess international tax planning by multinational enterprises (MNEs). Profit shifting to lower-tax rate countries is measured by comparing the profitability of MNE entities having different links to countries with different tax rates and thus different profit shifting opportunities. The paper also considers other aspects of tax planning that have been less documented in the empirical literature, such as the exploitation of mismatches between tax systems and preferential tax regimes, by comparing how profits reported by MNE entities are taxed relative to non-multinational entities with similar characteristics. The analysis builds on available unconsolidated financial account data, which, despite its limitations, is considered as the best existing cross-country firm-level data. Results are based on a very large sample of firms (1.2 million observations of MNE accounts) in 46 OECD and G20 countries and a sophisticated procedure to identify MNE groups. They provide robust evidence that MNEs shift profits to lower-tax rate countries and that large MNEs also exploit mismatches between tax systems and preferential tax treatment to reduce their tax burden. Overall, the estimated net tax revenue loss ranges from 4% to 10% of global corporate tax revenues. The empirical analysis also shows that strong “anti-avoidance” rules against tax planning are associated with reduced profit shifting, but also higher compliance costs for firms.
    Note: Zusammenfassung in französischer Sprache
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  • 2
    Language: English
    Pages: 1 Online-Ressource (circa 28 Seiten) , Illustrationen
    Series Statement: OECD Economics Department working papers no. 1357
    Keywords: Verbindlichkeiten ; Kapitalstruktur ; Multinationales Unternehmen ; Steuerplanung ; Eigenkapital ; OECD-Staaten ; Taxation ; Economics ; Amtsdruckschrift ; Arbeitspapier ; Graue Literatur
    Abstract: Multinational enterprises (MNEs) manipulate the location of their debts to reduce their corporate tax burden. Indeed, by locating debts in higher-tax rate countries, MNEs can deduct interest payments against a higher tax rate. This paper provides evidence of such manipulation of debt location. The analysis is based on a large sample of firm-level data from the ORBIS database. By comparing the indebtedness of MNE entities with similar characteristics but different debt shifting opportunities, the analysis suggests that a 1 percentage point higher tax rate is associated with 1.3% higher third-party debt. This is a lower bound estimate of debt manipulation, since it excludes the manipulation of internal debt. The analysis also shows that strict rules limiting interest deductibility (e.g. thin capitalisation or interest-to-earnings rules) can reduce debt manipulation. The possibility to locate debts in higher-tax rate countries reduces the effective cost of debt for MNE groups. The empirical analysis suggests that this can lead MNE groups to increase their overall external indebtedness, compounding the “debt bias” existing in most tax systems.
    Note: Zusammenfassung in französischer Sprache
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  • 3
    Language: English
    Pages: 1 Online-Ressource (circa 27 Seiten) , Illustrationen
    Series Statement: OECD Economics Department working papers no. 1360
    Keywords: Multinationales Unternehmen ; Unternehmensbesteuerung ; Innovationsmanagement ; IP-Management ; Steuerplanung ; Steuerrecht ; OECD-Staaten ; G20-Staaten ; BEPS, multinational enterprises, tax planning, patents, corporate taxation, research and development ; Taxation ; Economics ; Amtsdruckschrift ; Arbeitspapier ; Graue Literatur
    Abstract: This paper assesses the effect of international differences in taxes on the choice of patent location by multinational enterprises (MNEs). The analysis is based on a large sample of patents and firms from the OECD-PATSTAT and OECD-ORBIS databases over 2004-10. The approach is to compare the number of patent applications of MNE entities with different links to other countries and thus different sets of location choices, while controlling for other factors affecting patenting behaviour. The results suggest that lower corporate taxes, either in the form of a lower statutory rate or a preferential intellectual property regime, are associated with more patent applications. Both the location of research activities, which is proxied by the location of patent inventors, and the legal ownership of patents are found to be sensitive to corporate taxes. For instance, a 5 percentage point cut in the preferential tax rate on patent income is associated with a 6% increase in patent applications. On average, about two-thirds of the increase comes from patents invented at home and one third from patents invented abroad, but the relative importance of these two effects is likely to vary with the design of the preferential regime and especially the existence of activity requirements. In addition, strong anti-avoidance measures against tax planning are found to reduce patent shifting by MNEs.
    Note: Zusammenfassung in französischer Sprache
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  • 4
    Language: English
    Pages: 1 Online-Ressource (circa 17 Seiten) , Illustrationen
    Series Statement: OECD Economics Department working papers no. 1356
    Keywords: Multinationales Unternehmen ; Unternehmensbesteuerung ; Steuerplanung ; Steuerrecht ; Klassifikation ; OECD-Staaten ; G20-Staaten ; Taxation ; Economics ; Amtsdruckschrift ; Arbeitspapier ; Graue Literatur
    Abstract: This paper describes the main anti-avoidance rules against international tax planning by multinational enterprises in OECD and G20 countries. Building on this information and on previous classification efforts in the literature, a new classification of anti-avoidance strength is compiled. It takes into account five key dimensions of anti-avoidance: (i) transfer price rules and documentation requirements; (ii) rules on interest deductibility such as thin capitalisation and interest-to-earnings rules to prevent the manipulation of debt location; (iii) controlled foreign company (CFC) rules; (iv) general anti-avoidance rules (GAARs); and (v) withholding taxes on interest payments, royalties and dividends, taking into account bilateral tax treaties. The classification is based on a simple framework aiming to capture the main features of anti-avoidance rules in a harmonised way across countries, although it inevitably leaves aside certain country-specific characteristics as well as the enforcement of existing rules. The empirical analysis in Johansson et al., (2016), which is based on this classification, suggests that strong anti-avoidance rules can reduce profit shifting.
    Note: Zusammenfassung in französischer Sprache
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  • 5
    Language: English
    Pages: 1 Online-Ressource (circa 20 Seiten) , Illustrationen
    Series Statement: OECD Economics Department working papers no. 1359
    Keywords: Multinationales Unternehmen ; Unternehmensbesteuerung ; Auslandsinvestition ; Steuerplanung ; Steuerrecht ; Steuereinnahmen ; Welt ; Taxation ; Economics ; Amtsdruckschrift ; Arbeitspapier ; Graue Literatur
    Abstract: This paper assesses the redistribution of foreign direct investments (FDI) and tax revenues among countries due to multinationals’ response to international differences in corporate tax systems. The paper briefly reviews the literature on the tax sensitivity of FDI and uses a consensus estimate of this sensitivity in combination with bilateral FDI data to compute hypothetical bilateral FDI positions in the absence of tax rate differences. In a second step, tax revenue effects are estimated by assuming a conventional rate of return on investment. For most OECD countries, the effects of tax rate differentials on FDI positions range between -15% and 15% of current FDI positions. The calculated effects of taxes on FDI reflect real investments as well as tax planning behaviours and the methodology cannot distinguish between these two channels. The methodology only captures part of the tax planning activities of multinationals, since some of these activities are not reflected in the size of the FDI positions.
    Note: Zusammenfassung in französischer Sprache
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