We study how the OECD transfer pricing guidelines aimed at curbing tax-motivated transfer pricing practices affect investment incentives. Our theoretical model integrates the different OECD's transfer pricing methods into the tax planning cost function of an MNC to evaluate how the choice of...

The study evaluates the direct and moderating influence of Country-by-Country Reporting (CbCR) regulation in deterring corporate tax avoidance of multinational corporation listed in Indonesia Stock Exchange. The Indonesian CbCR stated in the regulations enacted by government of Indonesia namely...

Transfer pricing (TP) is based on many principles - the essential one is the Arm ́s Length Principle (ALP), In this respect, the term "associated persons" is of crucial importance: associated persons must be involved in transactions in order for the ALP to be applied, The aim of the paper is to...

We study how the OECD transfer pricing guidelines aimed at curbing tax-motivated transfer pricing practices affect investment incentives. Our theoretical model integrates the different OECD's transfer pricing methods into the tax planning cost function of an MNC to evaluate how the choice of...

To combat firms exploiting transfer pricing as a tool for tax avoidance, the Organisation for Economic Co-operation and Development (OECD) introduced the Base Erosion and Profit Shifting Action 13 (BEPS 13), enhancing tax transparency and the exchange of information with tax authorities....

In this paper we theoretically analyse the European Union's ongoing political impasse regarding the choice of a single method to allocate multinational enterprises' profits across countries and we find that this strategic situation resembles a coordination game with distributional consequences....

This paper reconsiders the empirical evidence of the relationship between tax treaties and FDI using U.S. outbound FDI to 78 countries over the period of 2007-2018. Unlike previous studies, we explicitly consider differences in the tax environments of recipient economies, including their...

Geschäfte mit Nahestehenden: Eine grundsätzliche Lösung für das Außensteuer-, Handels- und Gesellschaftsrecht - Unter besonderer Berücksichtigung von BEPS Bericht 8 und des Wettbewerbsrechts Gliederung 1. Einleitung 2. Wesentliche Ergebnisse der Untersuchung 3. Zusammenfassung 1....

Kürzlich hat die Verfasserin ihre Dissertation mit dem Titel „Geschäfte mit Nahestehenden: Eine grundsätzliche Lösung für das Außensteuer-, Handels- und Gesellschaftsrecht - Unter besonderer Berücksichtigung von BEPS Bericht 8 und des Wettbewerbsrechts“ veröffentlicht. Aufgrund der...

The main objective of this work is to assess the challenges to be faced by Brazil to become a full member of the Organisation for Economic Co-operation and Development (OECD) in terms of tax rules related to controlled foreign companies, transfer pricing, thin capitalization, and mandatory...

The purpose of the study is to analyze the practice of involving multinational companies in achieving the Sustainable Development Goals (SDGs), in general, and the response to SDG 16 "Peace, Justice and Strong Institutions". The research methodology involves a comparative analysis of the...

This paper reflects the tabled novel framework for corporate taxation in the European Union, founded on the Formulary Apportionment methodology and envisaged inclusion of intangible assets in the allocation formula. The objective is to simulate the variation between the currently used Separate...

The main objective of this work is to assess the challenges to be faced by Brazil to become a full member of the Organisation for Economic Co-operation and Development (OECD) in terms of tax rules related to controlled foreign companies, transfer pricing, thin capitalization, and mandatory...

Many federal tax systems employ formula apportionment to allocate the taxable profits of large businesses to the federal subunits, where the subunits' specific tax rates are then applied. The formulas - such as the one recently proposed by the EU Commission and the one agreed upon by the...

Zambia has changed its mineral tax regime repeatedly during the past decades in a bid to raise mineral revenue, but with only modest success. This paper looks at what the country needs to do to create a mining fiscal regime that could sustain operations, boost output, and raise revenues without...

This study investigates how strategic tax transfer pricing of a multinational company (MNC) and two tax authorities in different countries affects production and tax avoidance decisions at the firm level and tax revenues at the country level. We employ a game-theoretical model to analyze the...

This study investigates how strategic tax transfer pricing of a multinational company (MNC) and two tax authorities in different countries affects production and tax avoidance decisions at the firm level and tax revenues at the country level. We employ a game-theoretical model to analyze the...