CES Lecture Series. Tax Avoidance in Multinationals: The Case of Debt Shifting. Dirk Schindler (Norwegian School of Economics)
|
|
- Nigel Carter
- 8 years ago
- Views:
Transcription
1 CES Lecture Series Tax Avoidance in Multinationals: The Case of Debt Shifting Dirk Schindler (Norwegian School of Economics) Lecture 1: Background and Theory of Debt Shifting
2 What are we talking about? Tax avoidance (tax planning/tax engineering) use tax legislation to minimize tax payments tax planning can be done domestically or as arbitrage activity across states exploiting differences in tax codes what firms think is legal tax planning may be considered tax evasion by tax authorities grey area where unclear what is legal or not CES Lecture: The Case of Debt Shifting 2 Lecture 1: Background and Theory
3 Multinational companies affiliate(s) in at least one other country face international differences in tax rates profitable to shift income to low-tax countries various strategies to reduce global tax burden CES Lecture: The Case of Debt Shifting 3 Lecture 1: Background and Theory
4 Debt shifting fundamental asymmetry in corporate tax law: equity costs fully taxed interest expenses on debt tax deductible debt tax shield (simplest version: t i r D i ) strategically exploiting international allocation of debt across affiliates maximizes tax savings (international) debt shifting CES Lecture: The Case of Debt Shifting 4 Lecture 1: Background and Theory
5 The avoidance of taxes is the only intellectual pursuit that carries any reward. (John Maynard Keynes) CES Lecture: The Case of Debt Shifting 5 Lecture 1: Background and Theory
6 1 Stylized Facts Multinational companies World-wide growth rates (per annum) between 1985 and 1999 (Navaretti/Venables, 2004) (real) GDP: 2,5% / exports: 5,6% / FDI: 18% multinationals exponentially gaining importance one-third of global trade being trade within MNCs (Antràs, 2003) 40% of total US trade flows in 2008 being intra-firm exports and imports (Egger/Seidel, 2011) CES Lecture: The Case of Debt Shifting 6 Lecture 1: Background and Theory
7 Table 1.2: Top 10 countries with highest ratio of FDI flows as percentage of GDP ( ) Rank Country FDI Outflow (%) FDI Inflow (%) Sum of In- and Outflows (%) 1 Luxembourg Hong Kong (China) Singapore Iceland The Netherlands Belgium Ireland Lesotho Switzerland Bulgaria Sources: Mintz/Weichenrieder, 2010, based on IMF Statistics CES Lecture: The Case of Debt Shifting 7 Lecture 1: Background and Theory
8 Tax avoidance: Recent public incidents No taxes by global MNCs (e.g., Apple 1.9%, Google 2.5% on non-us profits) Starbuck s UK without tax payments in 14 out of last 15 years (Reuters/Bergin, 2012) Case study on Apple by US senate (Subcommittee Memorandum, 2013): Apple most egregious offender (Sen. John McCain) Apple sought the Holy Grail of tax avoidance (Sen. Carl Levin) CES Lecture: The Case of Debt Shifting 8 Lecture 1: Background and Theory
9 Tax avoidance Better access to tax-planning in multinationals Profit shifting in multinationals late-breaking political concern (OECD, UN-committee on tax havens) growing field in public finance In academia relevance well-known: Grubert/Mutti (1991, REaS), Hines/Rice (1994, QJE) Two main strategies (abusive) transfer pricing international debt shifting CES Lecture: The Case of Debt Shifting 9 Lecture 1: Background and Theory
10 2 Background: Tax-avoidance Strategies (Abusive) Transfer pricing Stylized facts Pak and Zdanowicz (2001): amounts to 18% of total reported US-corporate profits total volume 44.6 billion US-$ Bernard et al. (2006): total volume up to 33 billion US-$ Bartelsman and Beetsma (2003): reduces gain in revenue from tax increase by 65% - 87% CES Lecture: The Case of Debt Shifting 10 Lecture 1: Background and Theory
11 Main idea Over-/Underinvoicing intangibles, franchise fees, intermediates Shifting profits to low-tax affiliates Problem Transfer pricing disputed (illegal): concealment costs in hiding Transfer pricing in intermediate goods (prod. factors): potential distortion costs (depending on concealment costs) Transfer pricing in intangibles/fix costs potentially cheaper CES Lecture: The Case of Debt Shifting 11 Lecture 1: Background and Theory
12 CES Lecture: The Case of Debt Shifting 12 Lecture 1: Background and Theory
13 CES Lecture: The Case of Debt Shifting 13 Lecture 1: Background and Theory
14 International debt shifting Main idea: claim tax deductions in high tax countries External debt: loans from capital market load high-tax affiliates with external debt reduce external debt in low-tax affiliates maximize tax savings for given overall bankruptcy costs Internal debt: lending among related affiliates generate tax deductions in high tax affiliates declare interest income from internal debt in lowest-taxed affiliate utilize tax differential for tax savings CES Lecture: The Case of Debt Shifting 14 Lecture 1: Background and Theory
15 Table 1.3: Conduit entities of German MNC with positive net lending by country (2006) Country Lending to affiliated companies Number of conduit Statutory less liabilites (in Mio. euro) entities tax rate USA 53, UK 3, Switzerland France The Netherlands Belgium 2, Austria South Africa Luxembourg 1, Ireland Spain Sweden Canada Italy ,3725 Cayman Islands 4, Malta Sources: Ruf/Weichenrieder, 2012, MiDi database CES Lecture: The Case of Debt Shifting 15 Lecture 1: Background and Theory
16 Example: Statoil internal bank: coordination center in Mechelen/Belg. (since 1989) serving 130 affiliates worldwide / profit of 400 Mio. euro (2012) official aim: optimizing treasuring (NOT taxation) CES Lecture: The Case of Debt Shifting 16 Lecture 1: Background and Theory
17 Example: Statoil internal bank: coordination center in Mechelen/Belg. (since 1989) serving 130 affiliates worldwide / profit of 400 Mio. euro (2012) official aim: optimizing treasuring (NOT taxation) Coordination center in Belgium (until 2010) corporate tax base: costs minus wage and capital costs no tax burden on profits from interest received effective tax rate de facto zero Coordination-center regime replaced by Notional Interest Deductions (Belgian variant of ACE system) Internal banking no vehicle for tax planning and profit shifting? CES Lecture: The Case of Debt Shifting 17 Lecture 1: Background and Theory
18 Table 1.3: Conduit entities of German MNC with positive net lending by country (2006) Country Lending to affiliated companies Number of conduit Statutory less liabilites (in Mio. euro) entities tax rate USA 53, UK 3, Switzerland France The Netherlands Belgium 2, Austria South Africa Luxembourg 1, Ireland Spain Sweden Canada Italy ,3725 Cayman Islands 4, Malta Sources: Ruf/Weichenrieder, 2012, MiDi database CES Lecture: The Case of Debt Shifting 18 Lecture 1: Background and Theory
19 2.1 Questions: Economic Point of View How does tax-driven debt shifting work? How is a tax-efficient multinational structured? How large are the effects (e.g., on debt-to-asset ratio, on tax revenue)? What can be done to curb tax planning? CES Lecture: The Case of Debt Shifting 19 Lecture 1: Background and Theory
20 2.2 Questions: Finance Point of View How does (international) taxation affect firms value? What characterizes the optimal capital structure? In which sense are multinationals special? CES Lecture: The Case of Debt Shifting 20 Lecture 1: Background and Theory
21 3 Tax-efficient Capital Structures in Multinationals See Møen et al. (2011), Schindler and Schjelderup (2012) Distinctive features of multinational firms: facing international tax-rate differentials use of internal debt for tax reasons ability to shift (external and internal) debt across affiliates Improved capacities for tax avoidance CES Lecture: The Case of Debt Shifting 21 Lecture 1: Background and Theory
22 3.1 Model Price-taking multinational firm (henceforth: MNC) Production of homogenous good in i affiliates/countries Production function: x i = F(K i,l i ) Production factors: real capital K i, labor L i Decreasing marginal productivities in each factor CES Lecture: The Case of Debt Shifting 22 Lecture 1: Background and Theory
23 Small country assumption / well-functioning capital markets Constant rental cost of capital per unit r > 0 Tax-exemption principle dividends received from affiliates tax-free see, for example, Parent-Subsidiary directive of EU rare exception having no tax-exemption: USA Location of headquarters of MNC does not matter CES Lecture: The Case of Debt Shifting 23 Lecture 1: Background and Theory
24 Financing of investments in country i: E i = equity D E i = external debt (non-related third parties) D I i = internal debt (from other affiliates within MNC) CES Lecture: The Case of Debt Shifting 24 Lecture 1: Background and Theory
25 Leverage ratio in affiliate i: b i b E i +b I i external leverage: b E i D E i /K i internal leverage: b I i DI i /K i Internal lending constraint: r Di I = b I i r K i = 0 i i total sum of internal loans is zero CES Lecture: The Case of Debt Shifting 25 Lecture 1: Background and Theory
26 Affiliate-specific costs of debt External debt (cf. corp. finance lit.): U-shaped cost function C E (b E i ) Benefits: Capital market monitors firm / Reduction in moral hazard (e.g., limiting empire-building) Costs: Bankruptcy costs / Debt overhang Optimal leverage (in absence of taxation): b Internal debt: convex concealment costs C I (b I i ) Hiring tax experts (lawyers...) Avoiding thin cap rules and CFC taxation CES Lecture: The Case of Debt Shifting 26 Lecture 1: Background and Theory
27 Costs of debt fundamentally differing Internal debt de facto tax-preferred equity Assumption 3.1. External credit markets are assumed to be perfect except for the debt tax shield and financial distress costs. The cost function related to borrowing external and internal debt in affiliate i is additively separable, C(b E i,bi i ) = CE (b E i )+CI (b I i ), and exhibits C E (b E i ) > 0 with C E (b E i ) > 0, C E (b E i ) > 0, if b E i b, C E (b E i ) < 0, C E (b E i ) > 0, if b E i < b, C I (b I i) > 0 with C I (b I i) > 0, C I (b I i) > 0, if b I i > 0, C I (b I i) = 0 with C I (b I i) = 0, if b I i 0. CES Lecture: The Case of Debt Shifting 27 Lecture 1: Background and Theory
28 Overall bankruptcy costs on parent level MNC (partly) guarantees debt of affiliates Bankruptcy costs at parent level Costs depending on firm-wide leverage b f = ide i i K i Costs C f convex in firm-wide leverage CES Lecture: The Case of Debt Shifting 28 Lecture 1: Background and Theory
29 Profit equations Economic profit in affiliate i: π e i = F(K i,l i ) w L i [ r +C E (b E i )+C I (b I i) ] K i (3.1) Taxable profit in affiliate i (cost of equity not deductable) π t i = F(K i,l i ) w L i r [D E i +D I i] [C E (b E i )+C I (b I i)] K i (3.2) Affiliate s after-tax profit π i = π e i t i π t i = (1 t i ) [F(K i,l i ) w L i ] r K i } {{ } =V U i + t i r [D E i +D I i] (1 t i )[C E (b E i )+C I (b I i)] K i CES Lecture: The Case of Debt Shifting 29 Lecture 1: Background and Theory
30 World-wide profits and value of MNC Π p = V L = i V L i C f = i (π e i t i π t i) C f = i π i C f (3.3) Optimal capital structure (for fixed inputs K i, L i ) max D E i,di i Π p = i { (1 t i ) [F(K i,l i ) w i L i ] r K i (3.4) ] + t i r [D i E +Di I (1 ti ) [ C E (b E i )+C I (b I i) ] K } i C f (b f ) s.t. i r D I i = 0, (λ) s.t. b a i = Da i K i, a = {E,I}, b f = ide i i K i CES Lecture: The Case of Debt Shifting 30 Lecture 1: Background and Theory
31 3.2 Tax-efficient Capital Structure Rearranging the FOCs: t i r = (1 t i ) CE (b E i ) b E i + C f(b f ) b f 1 i K i > 0 i (3.5) (t i λ) r = (1 t i ) CI (b I i ) b I i 0 i (3.6) Lagrange parameter λ: shadow costs (tax payments) of shifted interest From equation (3.6): λ = min i t i = t 1 see Schindler and Schjelderup (2012a), Lemma 1 CES Lecture: The Case of Debt Shifting 31 Lecture 1: Background and Theory
32 Implications internal bank always located in lowest-taxed affiliate; i.e., country 1 maximizing internal debt tax shield / minimizing financing costs optimal to use both external and internal debt balancing debt tax shields (LHS) against (net) costs of debt (RHS) if C f = 0, identical external leverage in MNCs and domestic firms for C f = 0, MNCs affiliates have higher total leverage due to internal borrowing CES Lecture: The Case of Debt Shifting 32 Lecture 1: Background and Theory
33 Comparative-static analysis Implicit derivatives H(x,y) 0 dx dy = H/ y H/ x Effects of tax rate changes: differentiate FOCs (3.5) and (3.6) db E i dt i = r + C E / b E i (1 t i )( 2 C E / b E2 i )+( 2 C f / b 2 f ) > 0, (3.7) K i ( i K i) 2 db I i r + C I / b I i = dt i (1 t i )( 2 C I / b I2 > 0, i ) (3.8) db I i r = dt 1 (1 t i )( 2 C I / b I2 < 0. i ) (3.9) CES Lecture: The Case of Debt Shifting 33 Lecture 1: Background and Theory
34 Intuition increase in domestic tax rate t i increase of tax shield increase of tax subsidy on affiliate-specific debt costs external and internal leverage increase increase in tax rate of internal bank t 1 decrease of internal tax shields in all affiliates internal leverage decreases in affiliates i > 1 CES Lecture: The Case of Debt Shifting 34 Lecture 1: Background and Theory
35 3.3 Anecdotic Evidence and Illustration Statoil Coordination Center in Mechelen/BE (Aftenposten, ) equity from Statoil Norge (HQ): 12.4 billion euro loans to affiliates worldwide: 10.9 billion euro profit (in 2012): 400 million; effective tax rate: 8.4% 20 employees, all board members living in Norway Statkraft Treasury Sentre in Brussels/BE (Aftenposten, ) equity from Statkraft Norge (HQ): 7.6 billion euro loans to affiliates worldwide: 7.8 billion euro profit (in 2012): 330 million; effective tax rate: 12.4% 6 employees, 2 board members living in Norway CES Lecture: The Case of Debt Shifting 35 Lecture 1: Background and Theory
36 Formula One Holding Delta Topco (in 2011) Sylt and Reid (2011), The Independent (July 24, 2013) affiliates worldwide, mainly in Great Britain and on Jersey British affiliates loaded with 3.0 billion euro internal debt HMRC-allowed interest expense: 463 million euro interest rate on internal debt: 15% (confirmed by tax authorities) internal bank sitting on Channel Island Jersey Jersey well-known tax haven total tax payment: 1.1m euro in UK m euro overseas total revenues: 1.15 billion euro effective tax rate: 0.98% CES Lecture: The Case of Debt Shifting 36 Lecture 1: Background and Theory
37 CES Lecture: The Case of Debt Shifting 37 Lecture 1: Background and Theory
CES Lecture Series. Tax Avoidance in Multinationals: The Case of Debt Shifting. Dirk Schindler (Norwegian School of Economics)
CES Lecture Series Tax Avoidance in Multinationals: The Case of Debt Shifting Dirk Schindler (Norwegian School of Economics) Lecture 3: Regulation, Minority Ownership and Transfer Pricing as Limiting Factors
More informationA study of tax minimization strategies in multinational companies
Norwegian School of Economics Bergen, Spring 2014 A study of tax minimization strategies in multinational companies With focus on The Coca- Cola Company and IKEA Morten Randeberg & Helge Selvik Supervisor:
More informationInternational Debt Shifting:
University of Konstanz Dep artment of Economics International Debt Shifting: Do Multinationals Shift Internal or External Debt? Jarle Møen, Dirk Schindler, Guttorm Schjelderup, and Julia Tropina Working
More informationEliminating Double Taxation through Corporate Integration
FISCAL FACT Feb. 2015 No. 453 Eliminating Double Taxation through Corporate Integration By Kyle Pomerleau Economist Key Findings The United States tax code places a double-tax on corporate income with
More informationDebt Shifting and Thin-Capitalization Rules German Experience and Alternative Approaches
Debt Shifting and Thin-Capitalization Rules German Experience and Alternative Approaches Martin Ruf Eberhard Karls Universität Tübingen and NoCeT Dirk Schindler Norwegian School of Economics, NoCeT and
More informationGlobal Effective Tax Rates
www.pwc.com/us/nes Global s Global s April 14, 2011 This document has been prepared pursuant to an engagement between PwC and its Client. As to all other parties, it is for general information purposes
More informationMalta Companies in International Tax Structuring February 2015
INFORMATION SHEET No. 126 Malta in International Tax Structuring February 2015 Introduction Malta is a reputable EU business and financial centre with an attractive tax regime and sound legislative framework.
More informationTaxation of Canadian Inbound and Outbound Investments Duanjie Chen and Jack M. Mintz
Taxation of Canadian Inbound and Outbound Investments Duanjie Chen and Jack M. Mintz Research Report Prepared for the Advisory Panel on Canada s System of International Taxation December 2008 Taxation
More informationBLUM Attorneys at Law
BLUM Attorneys at Law CORPORATE TAXATION SYSTEM IN SWITZERLAND Outline of Swiss Corporate Tax System Levels of Taxation in Switzerland Resident companies are subject to: federal corporate income tax, and
More informationTHE TAX BURDEN ON CROSS-BORDER INVESTMENT: COMPANY STRATEGIES AND COUNTRY RESPONSES
THE TAX BURDEN ON CROSS-BORDER INVESTMENT: COMPANY STRATEGIES AND COUNTRY RESPONSES HARRY GRUBERT CESIFO WORKING PAPER NO. 964 CATEGORY 1: PUBLIC FINANCE JUNE 2003 PRESENTED AT CESIFO CONFERENCE ON MEASURING
More informationECON4620 Public Economics I Second lecture by DL
ECON4620 Public Economics I Second lecture by DL Diderik Lund Department of Economics University of Oslo 9 April 2015 Diderik Lund, Dept. of Econ., UiO ECON4620 Lecture DL2 9 April 2015 1 / 13 Outline
More informationHow do companies avoid tax?
How do companies avoid tax? Tax avoidance techniques for multinational companies are all about location. They consist of where a company chooses to open offices and create subsidiaries, and where it chooses
More informationMultinational firms, intellectual property and taxation
Multinational firms, intellectual property and taxation Rachel Griffith and Helen Miller Institute for Fiscal Studies 10 October 2013 Griffith and Miller (IFS) Multinational firms 10 October 2013 1 / 29
More informationINTERNAL DEBT AND MULTINATIONALS' PROFIT SHIFTING EMPIRICAL EVIDENCE FROM FIRM-LEVEL PANEL DATA. Thiess Buettner and Georg Wamser
INTERNAL DEBT AND MULTINATIONALS' PROFIT SHIFTING EMPIRICAL EVIDENCE FROM FIRM-LEVEL PANEL DATA Thiess Buettner and Georg Wamser National Tax Journal, forthcoming The paper explores the role of internal
More information- 1 - The Honorable Ron Wyden Chairman Committee on Finance United States Senate 219 Dirksen Senate Office Building Washington, D.C.
The Honorable Ron Wyden Chairman Committee on Finance United States Senate 219 Dirksen Senate Office Building Washington, D.C. 20510 The Honorable Orrin Hatch Ranking Member Committee on Finance United
More informationPrivate Company: SWEDEN
Private Company: SWEDEN Limited Liability Company [Aktiebolag /AB] Partnership [Handelsbolag / HB] Limited Partnership [Kommanditbolag / KB] Formation and Registration Bank Accounts Professional Administration
More informationINTERNAL DEBT AND MULTINATIONAL PROFIT SHIFTING: EMPIRICAL EVIDENCE FROM FIRM-LEVEL PANEL DATA
National Tax Journal, March 203, 66 (), 63 96 INTERNAL DEBT AND MULTINATIONAL PROFIT SHIFTING: EMPIRICAL EVIDENCE FROM FIRM-LEVEL PANEL DATA Thiess Buettner and Georg Wamser This paper explores the role
More informationForeign Taxes Paid and Foreign Source Income INTECH Global Income Managed Volatility Fund
Income INTECH Global Income Managed Volatility Fund Australia 0.0066 0.0375 Austria 0.0045 0.0014 Belgium 0.0461 0.0138 Bermuda 0.0000 0.0059 Canada 0.0919 0.0275 Cayman Islands 0.0000 0.0044 China 0.0000
More informationIn 2012, GNP in constant prices increased by 1.8% compared with 2011.
8 Economy In 2012, GNP in constant prices increased by 1.8% compared with 2011. The building and construction sector fell by 7.7% in value added terms in 2012 compared to 2011. Manufacturing industry decreased
More informationShafik Hebous and Alfons J. Weichenrieder. What Do We Know about the Tax Planning of German-Based Multinational Firms? White Paper No.
Shafik Hebous and Alfons J. Weichenrieder What Do We Know about the Tax Planning of German-Based Multinational Firms? White Paper No. 22 This paper was first published in the CESifo Dice Report 4/2014,
More informationChallenges of Taxing Financial Wealth
Challenges of Taxing Financial Wealth Gabriel Zucman (London School of Economics) November 2014 This talk: three points 1. The financial wealth held in offshore tax havens is large, rising, and seems largely
More informationDebt and equity finance and interest allocation rules
Debt and equity finance and interest allocation rules Background paper for Session 4 of the Victoria University of Wellington Tax Working Group October 2009 Prepared by the Policy Advice Division of the
More informationGreece Country Profile
Greece Country Profile EU Tax Centre March 2013 Key factors for efficient cross-border tax planning involving Greece EU Member State Double Tax Treaties With: Albania Estonia Lithuania Serbia Armenia Finland
More informationEvolution of Territorial Tax Systems in the OECD
www.pwc.com/us/nes Evolution of Territorial Tax Systems in the OECD Evolution of Territorial Tax Systems in the OECD April 2, 203 Prepared for The Technology CEO Council Evolution of Territorial Tax Systems
More informationTax-free. Welcome to the geography of tax avoidance. 1 Tax-free profits
Tax-free profits Welcome to the geography of tax avoidance 1 Tax-free profits International investment flows are often concentrated in countries with relatively small economies. Why? Welcome to the world
More informationDOING BUSINESS THROUGH MALTA - AN OVERVIEW
A. WHY MALTA 2 B. THE MALTESE COMPANY 2 C. MALTA TAX REFUNDS - LOWEST TAX IN THE EU 3 D. MALTESE TRADING STRUCTURE - 5% EFFECTIVE TAXATION Benefits and Uses of the Maltese Trading Company Basic Trading
More informationBelgium in international tax planning
Belgium in international tax planning Presented by Bernard Peeters and Mieke Van Zandweghe, tax division at Tiberghien Belgium has improved its tax climate considerably in recent years. This may be illustrated
More informationMALTA TRADING COMPANIES IN MALTA
MALTA TRADING COMPANIES IN MALTA Trading companies in Malta 1. An effective jurisdiction for international trading operations 410.000 MALTA GMT +1 Located in the heart of the Mediterranean, Malta has always
More information// BRIEF STATISTICS 2014
// BRIEF STATISTICS 2014 // TAXATION IN FINLAND Finland s taxation is subject to decisions by the Finnish Parliament, the European Union and the municipalities of Finland. It is governed by tax legislation,
More informationTax and Tax Incentive Effects on Investment and Policy Implications: ~ How does MNE tax planning factor in?
Organisation for Economic Co-operation and Development Tax and Tax Incentive Effects on Investment and Policy Implications: ~ How does MNE tax planning factor in? Workshop on Investment Incentives Joint
More informationTHE ADVANTAGES OF A UK INTERNATIONAL HOLDING COMPANY
THE ADVANTAGES OF A UK INTERNATIONAL HOLDING COMPANY Ideal Characteristics for the Location of an International Holding Company Laurence Binge +44 (0)1372 471117 laurence.binge@woolford.co.uk www.woolford.co.uk
More informationThe UK as a holding company location
The UK as a holding company location Tax May 2013 kpmg.com A key ambition is to create the most competitive tax system in the G20. As well as lowering tax rates, the Government wants to make the UK the
More informationInternational investment continues to struggle
FDI IN FIGURES December 2014 International investment continues to struggle Figures for the first half of 2014 point to stalled FDI flows Findings FDI fell in the first quarter of 2014 before rebounding
More informationReview of Current Practices for Taxation of Financial Instruments, Profits and Remuneration of the Financial Sector
TAXATION PAPERS WORKING PAPER N.31-2012 PwC Review of Current Practices for Taxation of Financial Instruments, Profits and Remuneration of the Financial Sector Taxation and customs union Taxation Papers
More informationApproaches to Improve the Competitiveness of the U.S. Business Tax System for the 21 st Century. Office of Tax Policy U.S. Department of the Treasury
Approaches to Improve the Competitiveness of the U.S. Business Tax System for the 21 st Century Office of Tax Policy U.S. Department of the Treasury December 20, 2007 Approaches to Improve the Competitiveness
More informationState of the Israeli Technology Industry and the Future. Dr. Orna Berry Venture Partner, Gemini Israel Funds
State of the Israeli Technology Industry and the Future Dr. Orna Berry Venture Partner, Gemini Israel Funds 2002 ICT GDP - NIS 33 billion 17% of business sector GDP. OECD highest - compared to 10-11% in
More informationOCTOBER 2010. Russell-Parametric Cross-Sectional Volatility (CrossVol ) Indexes Construction and Methodology
OCTOBER 2010 Russell-Parametric Cross-Sectional Volatility (CrossVol ) Indexes Construction and Methodology SEPTEMBER 2010 Russell-Parametric Cross-Sectional Volatility (CrossVol) Indexes Construction
More informationManaging payments from and to Latin America: Reducing your company's tax burden
Managing payments from and to Latin America: Reducing your company's tax burden Latin America 2010: Proactive Strategies for Doing Business in Today's Changing Landscape Miami, Florida March 17, 2010 Why
More informationExpenditure on Health Care in the UK: A Review of the Issues
Expenditure on Health Care in the UK: A Review of the Issues Carol Propper Department of Economics and CMPO, University of Bristol NIERC 25 April 2001 1 Expenditure on health care in the UK: The facts
More informationDEMOGRAPHICS AND MACROECONOMICS
1 UNITED KINGDOM DEMOGRAPHICS AND MACROECONOMICS Data from 2008 or latest available year. 1. Ratio of over 65-year-olds the labour force. Source: OECD, various sources. COUNTRY PENSION DESIGN STRUCTURE
More informationThe Special Non-resident Tax Regime for Expatriate Employees in Belgium
H UMAN C APITAL t The Special Non-resident Tax Regime for Expatriate Employees in Belgium Contents 1. Qualifying Conditions 2. The special tax regime a. Generalities b. Non-taxable allowances c. Calculation
More informationEXPORT-IMPORT BANK OF INDIA: Catalysing India s Trade and Investment. July 01, 2015
EXPORT-IMPORT BANK OF INDIA: Catalysing India s Trade and Investment July 01, 2015 INDIAN ECONOMY SNAPSHOT PARAMETER FY 2010 FY 2013 FY 2014 FY 2015 GDP (current prices, US$ bn) 1365.4 1835.8 1875.9 2050.6
More informationWACC and a Generalized Tax Code
WACC and a Generalized Tax Code Sven Husmann, Lutz Kruschwitz and Andreas Löffler version from 10/06/2001 ISSN 0949 9962 Abstract We extend the WACC approach to a tax system having a firm income tax and
More informationAfter making a clear distinction between the legal and economic ownership, van Bladel sets to define the beneficial ownership:
Page1 Gist of the News Tax Havens, Tax Evasion and Banking Secrecy According to Bloomberg.com on October 29, 2014: Governments around the world closed in on tax evaders with an automatic data-sharing agreement
More informationThe Perks of Doing Business in Malta
The Perks of Doing Business in Malta Legal and Tax Opportunities Dr Charles Cassar CCLex.com Malta London 1 2012 2013 - CCLex.com Overview About the Firm Business Environment Legal basics Tax Considerations
More informationHong Kong Companies. Their benefits for international investments, asset protection and market entry to China
Hong Kong Companies Their benefits for international investments, asset protection and market entry to China Presentation at the TaxPro 2013 Conference February 12, 2013 Kiev, Ukraine By Henning Schwarzkopf,
More informationThe Debt Challenge in Europe. Alan Ahearne and Guntram Wolff October 2011
The Debt Challenge in Europe Alan Ahearne and Guntram Wolff October 2011 Outline The challenge: debt overhang and price adjustment. Large increase in private debt prior to the crisis. Balance-sheet adjustments
More information41 T Korea, Rep. 52.3. 42 T Netherlands 51.4. 43 T Japan 51.1. 44 E Bulgaria 51.1. 45 T Argentina 50.8. 46 T Czech Republic 50.4. 47 T Greece 50.
Overall Results Climate Change Performance Index 2012 Table 1 Rank Country Score** Partial Score Tendency Trend Level Policy 1* Rank Country Score** Partial Score Tendency Trend Level Policy 21 - Egypt***
More informationA Comparison of the Tax Burden on Labor in the OECD
FISCAL FACT July 2015 No. 475 A Comparison of the Tax Burden on Labor in the OECD By Sam Jordan & Kyle Pomerleau Research Assistant Economist Key Findings Average wage earners in the United States face
More informationThe Tax Burden of Typical Workers in the EU 27 2013 Edition
(Cover page) The Tax Burden of Typical Workers in the EU 27 2013 Edition James Rogers & Cécile Philippe May 2013 Data provided by NEW DIRECTION Page 1 of 16 The Tax Burden of Typical Workers in the EU
More informationThe Determinants of Global Factoring By Leora Klapper
The Determinants of Global Factoring By Leora Klapper Factoring services can be traced historically to Roman times. Closer to our own era, factors arose in England as early as the thirteenth century, as
More informationWhat Are the Tax Reasons Favouring the United Kingdom as a Holding Company Location for International Groups?
UK CLIENT MEMORANDUM ENGLISH LAW UPDATES What Are the Tax Reasons Favouring the United Kingdom as a Holding Company Location May 13, 2014 AUTHOR Judith Harger Recent activity in the merger and M&A space
More informationFOREIGN TAXES AND THE GROWING SHARE OF U.S. MULTINATIONAL COMPANY INCOME ABROAD: PROFITS, NOT SALES, ARE BEING GLOBALIZED.
National Tax Journal, June 2012, 65 (2), 247 282 FOREIGN TAXES AND THE GROWING SHARE OF U.S. MULTINATIONAL COMPANY INCOME ABROAD: PROFITS, NOT SALES, ARE BEING GLOBALIZED Harry Grubert The foreign share
More informationCapital Structure and Taxes: What Happens When You (Also) Subsidize Equity?
June 2013 Capital Structure and Taxes: What Happens When You (Also) Subsidize Equity? Frédéric Panier, Francisco Pérez González y Pablo Villanueva Stanford University Paper Received the Jaime Fernández
More informationInequality and Taxation in a Globalised World. Dr Gabriel Zucman Department of Economics, LSE Associate on the Public Economics Programme, STICERD
Department of Economics and Centre For Macroeconomics public lecture Inequality and Taxation in a Globalised World Dr Gabriel Zucman Department of Economics, LSE Associate on the Public Economics Programme,
More informationPORTABILITY OF SOCIAL SECURITY AND HEALTH CARE BENEFITS IN ITALY
PORTABILITY OF SOCIAL SECURITY AND HEALTH CARE BENEFITS IN ITALY Johanna Avato Human Development Network Social Protection and Labor The World Bank Background study March 2008 The Italian Social Security
More informationA.2 The Prevalence of Transfer Pricing in International Trade
19. Transfer Prices A. The Transfer Price Problem A.1 What is a Transfer Price? 19.1 When there is a international transaction between say two divisions of a multinational enterprise that has establishments
More informationSummaries of the proposal from the Swedish Committee on Corporate Taxation
Summaries of the proposal from the Swedish Committee on Corporate Taxation This document contains a two-page executive summary and a sixpage full summary of the main proposal from the Swedish Committee
More informationOppor o t r unit i ie i s e s W it i hin i T h T e e M alt l e t s e e s e Fin i ancia i l l S ec e to t r o Banking
Opportunities Within The Maltese Financial Sector Banking Growth of the Industry Malta s international banking centre has been gaining considerable ground in establishing itself as a finance hub in the
More informationBANK FOR INTERNATIONAL SETTLEMENTS P.O. BOX, 4002 BASLE, SWITZERLAND
BANK FOR INTERNATIONAL SETTLEMENTS P.O. BOX, 4002 BASLE, SWITZERLAND PRESS RELEASE CENTRAL BANK SURVEY OF FOREIGN EXCHANGE AND DERIVATIVES MARKET ACTIVITY IN APRIL 1998: PRELIMINARY GLOBAL DATA The BIS
More informationU.S. DEPARTMENT OF THE TREASURY
U.S. DEPARTMENT OF THE TREASURY Press Center Link: http://www.treasury.gov/press-center/press-releases/pages/hp1060.aspx Statement For the Record of the Senate Committee on Finance Hearing on International
More informationACHIEVABLE CORPORATE TAX REFORM 2013 PETERSON INSTITUTE FOR INTERNATIONAL ECONOMICS DECEMBER 12, 2012
ACHIEVABLE CORPORATE TAX REFORM 2013 PETERSON INSTITUTE FOR INTERNATIONAL ECONOMICS DECEMBER 12, 2012 Gary Clyde Hufbauer, Reginald Jones Senior Fellow Martín Vieiro, Research Analyst Realistic Goals for
More informationEXTERNAL DEBT AND LIABILITIES OF INDUSTRIAL COUNTRIES. Mark Rider. Research Discussion Paper 9405. November 1994. Economic Research Department
EXTERNAL DEBT AND LIABILITIES OF INDUSTRIAL COUNTRIES Mark Rider Research Discussion Paper 9405 November 1994 Economic Research Department Reserve Bank of Australia I would like to thank Sally Banguis
More informationFinal Report: 7 February 2000. Stephen Bond and Lucy Chennells. The Institute for Fiscal Studies
Corporate Income Taxes and Investment: A Comparative Study Final Report: 7 February 2000 Stephen Bond and Lucy Chennells The Institute for Fiscal Studies 7 Ridgmount Street, London, WC1E 7AE, UK Acknowledgement:
More informationTax-efficient cross-border finance structures: opportunities and constraints
Tax-efficient cross-border finance structures: opportunities and constraints The increasing budget requirements of European countries and their implications for taxpayers CMS Annual Tax nference - Thursday
More informationHong Kong s Health Spending 1989 to 2033
Hong Kong s Health Spending 1989 to 2033 Gabriel M Leung School of Public Health The University of Hong Kong What are Domestic Health Accounts? Methodology used to determine a territory s health expenditure
More informationOwnership transfer Critical Tax Issues. Johan Fall, Anders Ydstedt March, 2010
Ownership transfer Critical Tax Issues Johan Fall, Anders Ydstedt March, 2010 Ownership transfer Critical Tax Issues 1 Ownership transfer Critical Tax Issues INTRODUCTION In tough economic times family
More informationAustralia s position in global and bilateral foreign direct investment
Australia s position in global and bilateral foreign direct investment At the end of 213, Australia was the destination for US$592 billion of global inwards foreign direct investment (FDI), representing
More informationTax Card 2013 With effect from 1 January 2013 Lithuania. KPMG Baltics, UAB
Tax Card 2013 With effect from 1 January 2013 Lithuania KPMG Baltics, UAB CORPORATE INCOME TAX Taxable profit of Lithuanian and foreign corporate taxpayers is subject to a standard (flat) rate of 15%.
More informationThe European Union Savings Tax Directive. An historic guide
The European Union Savings Tax Directive An historic guide Do you have any questions? This guide will tell you more If you are resident in an EU Member State and earn interest on deposits or investments
More informationInternational Investment. Australia. Economic Diplomacy, Trade Advocacy and Statistics Section Department of Foreign Affairs and Trade September 2015
International Investment Australia 214 International Investment Australia 214 Economic Diplomacy, Trade Advocacy and Statistics Section Department of Foreign Affairs and Trade September 215 ISSN 223-6571
More informationNetherlands Country Profile
Netherlands Country Profile EU Tax Centre March 2012 Key factors for efficient cross-border tax planning involving Netherlands EU Member State Yes Double Tax Treaties With: Albania Czech Rep. Jordan Nigeria
More informationTHE LOW INTEREST RATE ENVIRONMENT AND ITS IMPACT ON INSURANCE MARKETS. Mamiko Yokoi-Arai
THE LOW INTEREST RATE ENVIRONMENT AND ITS IMPACT ON INSURANCE MARKETS Mamiko Yokoi-Arai Current macro economic environment is of Low interest rate Low inflation and nominal wage growth Slow growth Demographic
More informationTurkish Arab Economic Forum June 29, 2012. Mehmet Şimşek. Minister of Finance
Turkish Arab Economic Forum June 29, 2012 Mehmet Şimşek Minister of Finance 1 Outline Turkey: Short Term Outlook Managing a Soft Landing Fallout from the Euro Crisis Turkey & MENA REBALANCING Growing ON
More informationHONG KONG RIGHT PLACE RIGHT TIME RIGHT NOW
HONG KONG RIGHT PLACE RIGHT TIME RIGHT NOW European Investment in China via Hong Kong Charles Ng Associate Director-General of Investment Promotion 22 May 2012 Agenda Changing Trends in the type of companies
More informationINVESTMENT FLOWS THROUGH OFFSHORE FINANCIAL HUBS DECLINED BUT REMAIN AT HIGH LEVEL. EMBARGO 3 MAY 2016, 13:00 GMT (09:00 New York, 15:00 Geneva)
No.23 3 MAY 2016 INVESTMENT FLOWS THROUGH OFFSHORE FINANCIAL HUBS DECLINED BUT REMAIN AT HIGH LEVEL EMBARGO 3 MAY 2016, 13:00 GMT (09:00 New York, 15:00 Geneva) HIGHLIGHTS In 2015, the volatility of investment
More informationTax Haven Legislation: Debunking the Myths
Spring Audit Session / Income Tax Conference Memphis, TN April 21, 2015 Tax Haven Legislation: Debunking the Myths Charles Fischer Sr. Manager, National Multistate Tax Services Deloitte Tax LLP chafischer@deloitte.com
More informationLecture 1: The intertemporal approach to the current account
Lecture 1: The intertemporal approach to the current account Open economy macroeconomics, Fall 2006 Ida Wolden Bache August 22, 2006 Intertemporal trade and the current account What determines when countries
More informationAustria A perfect gateway between East and West
Austria A perfect gateway between East and West Erich Certified Baier, Tax MBA, Advisor LL.M. 1 / 58 1 /77 Austria A A perfect gateway between East East and and West Wie auch immer das ausschauen 25 th
More informationForeign Direct Investment in the United States 2013 Report
Foreign Direct Investment in the United States 2013 Report ORGANIZATION FOR INTERNATIONAL INVESTMENT 1225 NINETEENTH STREET, NW, SUITE 501 WASHINGTON, DC 20036 WWW.OFII.ORG 202.659.1903 Overview Foreign
More informationA Comparison of the Tax Burden on Labor in the OECD By Kyle Pomerleau
FISCAL FACT Jun. 2014 No. 434 A Comparison of the Tax Burden on Labor in the OECD By Kyle Pomerleau Economist Key Findings Average wage earners in the United States face two major taxes: the individual
More informationGlobal Client Group The Gateway to AWM
Global Client Group The Gateway to AWM January 2013 For professional investors only Content 1 2 3 Deutsche Bank and Asset Global Client Group Our product and service offering 1 Deutsche Bank A global partner
More informationNew Zealand workers need higher wages, but simply wishing it will not make it so.
A COMPANY PHASED REDUCTION TAX RATES IN The company tax is the most damaging of all taxes to investment and innovation. Less investment equals less capital per worker, lower productivity, and lower wages
More informationInternational Tax Issues Affecting Multinationals. Presented by: Martin Kisuu, Director, Taxwise Consulting
International Tax Issues Affecting Multinationals Presented by: Martin Kisuu, Director, Taxwise Consulting Agenda International Tax issues affecting Multinationals At this point in time when many Kenyan
More informationMALTA TRADING COMPANIES
MALTA TRADING COMPANIES Malta Trading Companies Maltese Registered Companies and Trading Operations in Malta Malta, an EU Member State since May 2004, has developed into a leading and reputable financial
More informationThe Norwegian economy
The Norwegian economy Slower speed ahead, but still growth Strong mechanisms support mainland economy Wriggle room to smooth business cycles Rune Bjerke CEO Just how bad is it? Slower speed ahead but still
More informationTopics in the Economics of International Taxation (2): Tax Havens and Tax Holidays
Topics in the Economics of International Taxation (2): Tax Havens and Tax Holidays Center for Economic Studies Ludwig-Maximilians-Universität Munich 27 July, 2011 Dhammika Dharmapala University of Illinois
More informationUS Real Estate Funds. Structures to Maximize Net Returns to Non-US Investors
US Real Estate Funds Structures to Maximize Net Returns to Non-US Investors This paper was prepared for the general information of our clients and other interested persons. Due to space limitations and
More informationHow Costly is the Tax Bias Toward Debt in the Global Economy?
How Costly is the Tax Bias Toward Debt in the Global Economy? IIPF Congress Taxation in a Global Economy August 21, 2015 Dublin Keynote Lecture Ruud de Mooij Views are authors alone, and should not be
More informationOHIO. The European Union. Why the EU Matters for the Buckeye State. Indiana University. European Union Center
OHIO & The European Union Why the EU Matters for the Buckeye State Indiana University European Union Center Table of Contents Why does the EU Matter? 1 Ohio s Trade with the EU 2 The EU s Investments in
More informationAn Analysis of Where American Companies Report Profits: Indications of Profit Shifting
An Analysis of Where American Companies Report Profits: Indications of Profit Shifting Mark P. Keightley Specialist in Economics January 18, 2013 CRS Report for Congress Prepared for Members and Committees
More informationDeutsche Global Infrastructure Fund (TOLLX)
Global Infrastructure Fund (TOLLX) A step beyond MLPs Important risk information Any fund that concentrates in a particular segment of the market will generally be more volatile than a fund that invests
More informationWELCOME! Introduction. Celebrating. &PrimeRevenue. PrimeRevenue Hong Kong. 2012 PrimeRevenue, Inc.
WELCOME! Introduction Celebrating Ethe Factor Network establishment of &PrimeRevenue PrimeRevenue Hong Kong 2012 PrimeRevenue, Inc. Global Reach Today, we transact business in 50 countries Our platform
More informationFifth European Meeting of Employee Ownership
Fifth European Meeting of Dexia Brussels, 17 June 2005 Executive summary Dexia in the world and its activities Dexia Case study 2 Executive summary Dexia in the world and its activities Dexia Case study
More informationInterest Deductibility for UK Corporation Tax. Michael P. Devereux Socrates Mokkas James Pennock Peter Wharrad
Interest Deductibility for UK Corporation Tax Michael P. Devereux Socrates Mokkas James Pennock Peter Wharrad December 2006 Oxford University Centre for Business Taxation Saïd Business School Park End
More informationOrder of creditor and shareholder ranking on a company s insolvency
Order of creditor and shareholder ranking on a company insolvency This table is part of the PLC multi-jurisdictional guide to restructuring and insolvency law. For a full list of jurisdictional Q&As visit
More informationAppendix 3. The metric
Appendix 3 A consistent and useful effective tax rate methodology to assess the global tax performance of multinationals in relation to Australian-linked business operations 1 The purpose of this paper
More informationBIS database for debt service ratios for the private nonfinancial
BIS database for debt service ratios for the private nonfinancial sector Data documentation The debt service ratio (DSR) is defined as the ratio of interest payments plus amortisations to income. As such,
More informationInvesting in the United States
Investing in the United States 13 May 2015 ehealth Week 2015 Global Markets: Tools for Transatlantic Trade Kim Tuminaro Senior Trade Officer U.S. Department of State SelectUSA.gov U.S. Investment and Business
More informationSURVEY OF INVESTMENT REGULATION OF PENSION FUNDS. OECD Secretariat
SURVEY OF INVESTMENT REGULATION OF PENSION FUNDS OECD Secretariat Methodological issues The information collected concerns all forms of quantitative portfolio restrictions applied to pension funds in OECD
More information