Table 4 - uploaded by Thomas Rixen
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There are two largely distinct bodies of literature and corresponding research areas in international taxation. On the one hand, there is the big and continuously growing body of theoretical and empirical literature on tax competition, mainly in the field of economics; on the other, there is a large body of mostly legal literature dealing with inte...
Context in source publication
Context 1
... Positive values are found in cases when loss carry-forwards are available to the affiliate. Bernard et al. (2008) Outcome(s): The paper shows that the wedge between the arm's-length export price and the intra-firm export price of US-based multinationals is negatively related to the taxation of corporate income in the foreign import country; this response indicates that tax-motivated transfer pricing is present in intra-firm export prices of US-based multinational companies Years and countries included: 1993-2000; the United States and 140 partner countries Specification and estimator applied: Log-level specification; pooled OLS with product fixed effects Dependent variable: The dependent variable is the wedge between the arm's- length export price and the intra-firm export price of US-based multination- als; data from the Linked/Longitudinal Firm Trade Transaction Database (LFTTD), which is based on data from the US Census Bureau and the US Customs Bureau, are used Tax variable of main interest: Statutory tax rate on corporate income and average tax rate on corporate income in the host country of US-based multinationals' affiliates Control variables: Tariff rate, log(employment of the affiliate), firm export share, log(real exchange rate with the US dollar), 10g(GDP per capita) Semi-elasticities Table 14 Semi-elasticity mean Semi-elasticity min. Semi-elasticity max. ...
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Citations
... Only a er the issue of double taxation had been addressed did the issue of undertaxation, which the separate entity principle facilitated, become relevant. 19 A er the Second World War, the work to abolish double taxation continued rst as an Organisation for Economic Development and Co-operation (OECD)-led initiative. 20 e Paris-based organization advocated a generally more hands-o approach to economic a airs compared to the more Keynesian mainstream ideas of the time. ...
... Only a er the issue of double taxation had been addressed did the issue of undertaxation, which the separate entity principle facilitated, become relevant. 19 A er the Second World War, the work to abolish double taxation continued rst as an Organisation for Economic Development and Co-operation (OECD)-led initiative. 20 e Paris-based organization advocated a generally more hands-o approach to economic a airs compared to the more Keynesian mainstream ideas of the time. ...
This chapter focuses on corporate power and corruption, providing context for current debates around responsibility for and the consequences of tax abuse. In addition to the already discussed problems of tax avoidance and tax evasion, the bargaining power of large corporations over smaller states is also an outcome of structural problems that discourage developing countries from collecting taxes needed for human development. Here, a key problem is international tax competition, or more accurately tax wars between nations. This international pressure pushes decision makers in developing countries to turn a blind eye to corporate wrongdoings and to offer tax breaks and other sweeteners to large enterprises in exchange for investments. Ultimately, what is needed are more comprehensive frameworks for analyzing the reasons behind the obstacles to domestic resource mobilization, which pay close attention to both public and private factors that prevent the fulfillment of social rights and development goals.
The international regime or “transnational legal order” (TLO) (Shaffer & Halliday this volume) of taxation consists of a body of multilateral, bilateral, and unilateral hard and soft laws regulating the tax treatment of cross-border economic activities, especially investment activities. The chapter reconstructs the dynamics of change of this TLO since its creation in the 1920s. Taking a diachronic perspective, it shows how the initial success of the TLO in establishing a settled normative order for avoiding the international double taxation of cross-border economic activities unintentionally created the follow-up problem of international tax competition. This triggered a new cycle of transnational legal ordering that challenged the initial settlement. The result is a TLO covering more issues at lower levels of normative settlement and with lower issue alignment.
