Podcast
Questions and Answers
How do taxes impact the target value of an investment or consumption?
How do taxes impact the target value of an investment or consumption?
- Taxes can change the target value (e.g., present value of an investment, level of consumption). (correct)
- Taxes have no impact on the target value as they are external factors.
- Taxes only affect the target value for domestic investments, not international ones.
- Taxes always increase the target value by a fixed percentage.
Which of the following best describes 'tax neutrality'?
Which of the following best describes 'tax neutrality'?
- Decision-making that remains unaffected by the presence of taxes. (correct)
- A system where tax rates are the same across all countries.
- Taxation that disproportionately affects specific sectors of the economy
- A situation where taxes intentionally stimulate certain economic behaviors.
What is a key characteristic of 'tax distortion'?
What is a key characteristic of 'tax distortion'?
- It reduces complexity in the taxation system.
- It discriminates between different alternatives. (correct)
- It is designed to create tax neutrality.
- It ensures all alternatives are taxed equally.
What role do tax revenues primarily play in a country's economy?
What role do tax revenues primarily play in a country's economy?
Why is the international dimension of taxes becoming increasingly relevant?
Why is the international dimension of taxes becoming increasingly relevant?
How can taxes influence a country's attractiveness as a business location?
How can taxes influence a country's attractiveness as a business location?
What complicates the taxation of multinational firms in the global economy?
What complicates the taxation of multinational firms in the global economy?
What is a key characteristic that distinguishes multinational firms (MNEs) and makes taxing them complex?
What is a key characteristic that distinguishes multinational firms (MNEs) and makes taxing them complex?
Why is intra-firm trade significant in the context of taxing multinational firms?
Why is intra-firm trade significant in the context of taxing multinational firms?
According to the content, what is a primary motivation for MNEs to re-allocate profits globally?
According to the content, what is a primary motivation for MNEs to re-allocate profits globally?
How does the Separate Entity Approach affect tax collection from multinational firms?
How does the Separate Entity Approach affect tax collection from multinational firms?
How can international tax integration and firm mobility affect taxation?
How can international tax integration and firm mobility affect taxation?
What is a key factor that might cause a mobile multinational enterprise (MNE) to shift its activity to another region?
What is a key factor that might cause a mobile multinational enterprise (MNE) to shift its activity to another region?
Why are countries concerned about the activities of multinational enterprises (MNEs)?
Why are countries concerned about the activities of multinational enterprises (MNEs)?
According to the content, what can be considered a benefit provided by multinational enterprises (MNEs) to host countries?
According to the content, what can be considered a benefit provided by multinational enterprises (MNEs) to host countries?
What is the general policy consequence of strictly limiting tax discrimination against foreign investors?
What is the general policy consequence of strictly limiting tax discrimination against foreign investors?
What is the intended goal of the OECD's work on concepts for a more coordinated approach to international taxation?
What is the intended goal of the OECD's work on concepts for a more coordinated approach to international taxation?
What characterizes tax evasion, as opposed to tax avoidance?
What characterizes tax evasion, as opposed to tax avoidance?
What is a key difficulty distinguishing tax avoidance from legitimate tax planning?
What is a key difficulty distinguishing tax avoidance from legitimate tax planning?
In relation to corporate taxation, what does the 'tax base' refer to?
In relation to corporate taxation, what does the 'tax base' refer to?
What distinguishes financial accounting rules from tax accounting?
What distinguishes financial accounting rules from tax accounting?
In terms of priorities, how do financial profits differ from taxable profits?
In terms of priorities, how do financial profits differ from taxable profits?
Which of the following is true regarding most countries' method of determining taxable profit?
Which of the following is true regarding most countries' method of determining taxable profit?
Which of the following could cause differences in the tax base?
Which of the following could cause differences in the tax base?
Which of the following describes an effect of the depreciation scheme used?
Which of the following describes an effect of the depreciation scheme used?
Why are depreciation rules relevant for tax planning?
Why are depreciation rules relevant for tax planning?
What generally happens if provisions are permitted to be formed under tax law?
What generally happens if provisions are permitted to be formed under tax law?
Symmetric treatment of profits and losses in taxation implies what?
Symmetric treatment of profits and losses in taxation implies what?
Which of the following best describes how a loss carry-forward affects the deductibility of prior years if profits appear after losses?
Which of the following best describes how a loss carry-forward affects the deductibility of prior years if profits appear after losses?
What factors make the value of loss carry-forward benefits uncertain?
What factors make the value of loss carry-forward benefits uncertain?
According to the content, what is the primary purpose of allowing a notional interest deduction (NID)?
According to the content, what is the primary purpose of allowing a notional interest deduction (NID)?
In what scenario is the tax benefit of notional interest deduction most pronounced?
In what scenario is the tax benefit of notional interest deduction most pronounced?
According to the introduction to the topic, which of the following is true regarding separate legal entities of MNE?
According to the introduction to the topic, which of the following is true regarding separate legal entities of MNE?
What distinguishes tax strategies, such as in innovation-heavy technology firms like Amazon or Google?
What distinguishes tax strategies, such as in innovation-heavy technology firms like Amazon or Google?
What best describes IP Box Regimes?
What best describes IP Box Regimes?
What is a possible consequence of Innovation Tax Box Strategies?
What is a possible consequence of Innovation Tax Box Strategies?
The domestic tax rules on foreign income are also based on which international principle?
The domestic tax rules on foreign income are also based on which international principle?
If a company is effectively connected to the territory of a country, that means:
If a company is effectively connected to the territory of a country, that means:
Which situation can cause economic double taxation?
Which situation can cause economic double taxation?
What does the international standard for Double Taxation by OCED dictate?
What does the international standard for Double Taxation by OCED dictate?
What is the most direct impact of multinational enterprises (MNEs) on national tax policies?
What is the most direct impact of multinational enterprises (MNEs) on national tax policies?
Why is it difficult to determine a fair price for transactions within multinational companies?
Why is it difficult to determine a fair price for transactions within multinational companies?
Which factor most directly motivates multinational enterprises (MNEs) to engage in international tax planning?
Which factor most directly motivates multinational enterprises (MNEs) to engage in international tax planning?
In the context of multinational enterprises (MNEs), what does the Separate Entity Approach entail?
In the context of multinational enterprises (MNEs), what does the Separate Entity Approach entail?
How does the mobility of multinational enterprises (MNEs) impact a country's tax policy options?
How does the mobility of multinational enterprises (MNEs) impact a country's tax policy options?
What constitutes a significant economic benefit that multinational enterprises (MNEs) can bring to a host country?
What constitutes a significant economic benefit that multinational enterprises (MNEs) can bring to a host country?
What is a key consideration when evaluating the impact of taxes on investment decisions?
What is a key consideration when evaluating the impact of taxes on investment decisions?
Why might a country choose to offer tax incentives?
Why might a country choose to offer tax incentives?
What factor has increased the relevance of international taxation?
What factor has increased the relevance of international taxation?
What is a key factor determining a country's attractiveness for multinational firms?
What is a key factor determining a country's attractiveness for multinational firms?
What is the primary difference between financial and tax accounting?
What is the primary difference between financial and tax accounting?
What is the primary aim when establishing accounting rules for financial profits?
What is the primary aim when establishing accounting rules for financial profits?
In most countries, what serves as the basis for calculating taxable profit?
In most countries, what serves as the basis for calculating taxable profit?
What can be the effect of differences in stock valuation methods (LIFO, FIFO, Weighted Average) on the tax base?
What can be the effect of differences in stock valuation methods (LIFO, FIFO, Weighted Average) on the tax base?
What is a key aspect regarding depreciation methods in tax planning?
What is a key aspect regarding depreciation methods in tax planning?
If tax law permits the formation of provisions, what usually results?
If tax law permits the formation of provisions, what usually results?
What does symmetric treatment of profits and losses imply in taxation?
What does symmetric treatment of profits and losses imply in taxation?
What factor would most likely reduce the actual value of a loss carry-forward?
What factor would most likely reduce the actual value of a loss carry-forward?
What is the primary aim of allowing a Notional Interest Deduction (NID) for corporate equity?
What is the primary aim of allowing a Notional Interest Deduction (NID) for corporate equity?
Which scenario provides the greatest tax benefit from a notional interest deduction?
Which scenario provides the greatest tax benefit from a notional interest deduction?
What is a key factor that contributes to the rise of tax competition among countries?
What is a key factor that contributes to the rise of tax competition among countries?
What limits the extent to which smaller countries can effectively compete with lower corporate tax rates?
What limits the extent to which smaller countries can effectively compete with lower corporate tax rates?
What is leading to a decrease in corporate income tax rates in some larger economies?
What is leading to a decrease in corporate income tax rates in some larger economies?
A key aspect that can result in double taxation or non-taxation?
A key aspect that can result in double taxation or non-taxation?
What are the aims of coordinated international efforts to combat tax avoidance?
What are the aims of coordinated international efforts to combat tax avoidance?
In transfer pricing which requirement limits setting prices?
In transfer pricing which requirement limits setting prices?
When is debt and equity are treated equally in taxation?
When is debt and equity are treated equally in taxation?
To be a special tax regime, what is the focus to be implemented in a country?
To be a special tax regime, what is the focus to be implemented in a country?
What does the benefit of IP box regimes further depends on?
What does the benefit of IP box regimes further depends on?
What is a result from Germany being a high tax country?
What is a result from Germany being a high tax country?
Why a tax payers arrange their business in order to minimize taxes?
Why a tax payers arrange their business in order to minimize taxes?
According to the data is it possible to tax MNE at lower rates than domestic market?
According to the data is it possible to tax MNE at lower rates than domestic market?
A company is considering two investment options, A and B. Option A is taxed at 50% while B is taxed at 10%. What step is recommended?
A company is considering two investment options, A and B. Option A is taxed at 50% while B is taxed at 10%. What step is recommended?
What is a type of a non-profit tax from the corporate level?
What is a type of a non-profit tax from the corporate level?
When does taxation of capital is paid at the time?
When does taxation of capital is paid at the time?
What is a purpose of allowing a notional interest deduction (NID)?
What is a purpose of allowing a notional interest deduction (NID)?
A high equity capital can lead to
A high equity capital can lead to
The belgium case showed that the notional interest deduction is heavily used for
The belgium case showed that the notional interest deduction is heavily used for
Some multinational enterprises establish finance holdings in Belgium to:
Some multinational enterprises establish finance holdings in Belgium to:
If NID/ACE narrows the tax base, puts pressure on governments to increase:
If NID/ACE narrows the tax base, puts pressure on governments to increase:
Revenues consequences, tax arbitrage and distributive issues are:
Revenues consequences, tax arbitrage and distributive issues are:
Which of the following best characterizes the nature of a tax treaty?
Which of the following best characterizes the nature of a tax treaty?
What is the effect of double taxation?
What is the effect of double taxation?
An investor may have a large profit investment with a high percentage, however, when is that not an advantage?
An investor may have a large profit investment with a high percentage, however, when is that not an advantage?
What primary factor enables multinational enterprises (MNEs) to benefit from tax advantages worldwide?
What primary factor enables multinational enterprises (MNEs) to benefit from tax advantages worldwide?
What is the primary result of each separate legal entity within a multinational enterprise (MNE) being taxed individually?
What is the primary result of each separate legal entity within a multinational enterprise (MNE) being taxed individually?
What is a key incentive for multinational enterprises (MNEs) to strategically re-allocate profits on a global scale?
What is a key incentive for multinational enterprises (MNEs) to strategically re-allocate profits on a global scale?
What factor might prompt a mobile multinational enterprise (MNE) to relocate its activities to a different country?
What factor might prompt a mobile multinational enterprise (MNE) to relocate its activities to a different country?
Why are countries increasingly focused on the tax policies and actions of multinational enterprises (MNEs)?
Why are countries increasingly focused on the tax policies and actions of multinational enterprises (MNEs)?
What impact does the European Court of Justice (ECJ) have on tax discrimination between local and foreign investors?
What impact does the European Court of Justice (ECJ) have on tax discrimination between local and foreign investors?
How has the decline in corporate income tax rates in some larger economies affected tax competition?
How has the decline in corporate income tax rates in some larger economies affected tax competition?
What constitutes tax avoidance?
What constitutes tax avoidance?
What is the primary goal when accounting rules are established for financial profits?
What is the primary goal when accounting rules are established for financial profits?
What is the starting point for determining taxable profit in most countries?
What is the starting point for determining taxable profit in most countries?
What is a potential fiscal outcome when tax law allows for the formation of a provision, such as for warranty obligations?
What is a potential fiscal outcome when tax law allows for the formation of a provision, such as for warranty obligations?
What is meant by the symmetric tax treatment of profits and losses?
What is meant by the symmetric tax treatment of profits and losses?
What is the primary function of allowing a Notional Interest Deduction (NID)?
What is the primary function of allowing a Notional Interest Deduction (NID)?
When is the benefit from allowing NID most notable?
When is the benefit from allowing NID most notable?
What are some key implementation challenges for special tax regimes?
What are some key implementation challenges for special tax regimes?
The generosity of the IP box system further depends on one of what factors?
The generosity of the IP box system further depends on one of what factors?
What describes international dimensions?
What describes international dimensions?
When is decision based on financial accounting standards not an advantage to an investor?
When is decision based on financial accounting standards not an advantage to an investor?
Which nations have the lowest tax rates in Europe, that allow for a high amount of tax revenue?
Which nations have the lowest tax rates in Europe, that allow for a high amount of tax revenue?
The effective tax burdens depend on
The effective tax burdens depend on
Flashcards
Tax neutrality
Tax neutrality
Decision making unaffected by taxes
Tax distortion
Tax distortion
Tax which discriminates between alternatives
Tax incentives
Tax incentives
Intentionally introduced to stimulate certain behavior
International Transactions
International Transactions
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MNE profit allocation
MNE profit allocation
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Separate entity taxation
Separate entity taxation
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Global profit shifting
Global profit shifting
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Taxpayer right
Taxpayer right
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Tax Evasion
Tax Evasion
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Tax planning
Tax planning
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Tax Avoidance
Tax Avoidance
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Effective place of management
Effective place of management
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Corporate income tax
Corporate income tax
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Depreciation
Depreciation
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Depreciation scheme
Depreciation scheme
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Straight-line depreciation
Straight-line depreciation
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Declining-balance depreciation
Declining-balance depreciation
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Provisions
Provisions
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Symmetric treatment
Symmetric treatment
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Loss carry-back
Loss carry-back
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Tax loss compensation
Tax loss compensation
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Non-profit taxes
Non-profit taxes
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Profit taxes
Profit taxes
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Capital/payroll tax
Capital/payroll tax
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Corporate tax
Corporate tax
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Debt finacing advantage
Debt finacing advantage
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Tax system with debt
Tax system with debt
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Tax divends and interest
Tax divends and interest
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Additional debt incentive
Additional debt incentive
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Higher debt level
Higher debt level
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Financial limits
Financial limits
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Deduction of equity
Deduction of equity
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Synonym for Equity-ACE
Synonym for Equity-ACE
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Debt equity bias removal
Debt equity bias removal
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Tax discrimination
Tax discrimination
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Inveseted quity
Inveseted quity
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Rely on tax incentives
Rely on tax incentives
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Notional Intrest deduction
Notional Intrest deduction
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Innovation box regimes
Innovation box regimes
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Shifting Tax burdens
Shifting Tax burdens
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European Court of Justice
European Court of Justice
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Anti Tax legislation
Anti Tax legislation
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OECD and EU Commission
OECD and EU Commission
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Tax stratagies
Tax stratagies
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Tax Evasion
Tax Evasion
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Tax avoidance
Tax avoidance
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Use tax provision
Use tax provision
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Multination exploitation
Multination exploitation
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Taxes combat loopholes
Taxes combat loopholes
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Tax differences with economic
Tax differences with economic
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Tax rate impacts
Tax rate impacts
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Rate are important
Rate are important
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Generate taxes
Generate taxes
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Tax cut effects
Tax cut effects
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OECD globe Minimum
OECD globe Minimum
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tax rates
tax rates
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Tax cut
Tax cut
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Benefits in many locations
Benefits in many locations
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Minimizing rules
Minimizing rules
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Savings vs Equity
Savings vs Equity
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Equity debt firm structure
Equity debt firm structure
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Transfer changes
Transfer changes
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Profits globe access
Profits globe access
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Investment choices tax
Investment choices tax
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Rules globally
Rules globally
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Always review taxes double
Always review taxes double
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Study Notes
Taxes and Business Decisions
- Taxes have an affect on target value including the present value of investment or the level of consumption
- Taxes can alter the optimal choice between different alternatives, and will effect decision making
- Tax neutrality means the decision making is unaffected by taxes
- Tax distortion occurs where tax discriminates between alternatives
- Tax incentives are intentionally introduced to stimulate certain behaviours
Tax Revenue and International Tax
- Tax revenues are the primary source of government spending
- The international dimension of taxes is increasingly relevant
- More and more transactions involve greater than one country
- Taxes are a location factor for businesses
- Nations use taxes as a tool in global competition
- The international integration and mobility of firms complicates the taxation of multinational firms
Example of Taxes Altering Investment Choice
- Consider two investments, A and B, that both require an investment of EUR 100,000
- Return on investment A is 8% and is taxed at 50%
- Return on investment B is 5% and is taxed at 10%
- Without taxes, invesment A (100,000 x 1.08 = 108,000) is the optimal choice, due to larger returns then investment B (100,000 x 1.05 = 105,000)
- With taxes on Investment A (100,000 x (1 + 0.08 x (1 - 0.5)) = 104,000) and taxes on investment B (100,000 x (1 + 0.05 x (1 - 0.1)) = 104,500) investment B becomes the better choice
Special Aspects of Multinational Firms (MNE)
- MNE have complex global structure, with many cross-border transactions
- MNE participate in intra-firm trade of highly specific goods
- MNE maintain highly mobile investments and profits, taking advantage of the digital economy
Why are MNEs Difficult to Tax?
- Each separate legal entity is taxed, so profits of multinational grops are not consolidated
- Cross-border taxation may result in either double taxation or non-taxation
- There is an incentive to re-allocate profits globally to save taxes
- This includes the pricing intra group transactions, strategic debt financing and relocation of intangibles
- It is hard to find adequate pricing for highly specific intra group transactions
- Mobile MNEs might shift their activity elsewhere if local taxes are too high
Why Do Countries Care About MNE Activity?
- Multinationals often have significant economic power, comparable to middle-income countries
- MNEs are highly productive and profitable
- MNEs offer jobs, growth opportunities and knowledge spillover
Tax Policy Consequences
- Tax burdens shift to workers, shareholders, and consumers
- The ECJ limits discrimination between local and foreign investors
- Anti-avoidance legislation has been introduced
- The OECD and the EU Commission are working on concepts for coordinated regulation
- This includes things like the EU Anti Tax Avoidance Directive (ATAD)
- OECD/G20 BEPS report and OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting are also being explored
Tax Evasion vs Tax Avoidance vs Tax Planning
- Taxpayers have the right to arrange their business to minimize taxes
- Tax evasion is illegal
- Tax avoidance is behavior where a behaviour is solely driven by using tax with certain means
- In tax planning there is using known as of tax provisions with the purpose to minimize a parties tax burden
Course Outline and Topics
- Main features of the tax system, Special Tax Regimes and Fundamentals of International Taxation are three major topics of Tax Systems
- An understanding of Basic Tax Planning Strategies for Cross-Border Investments & Ongoing international developments is key
- A main feature is focusing on Tax Rates on Corporate Income
- It is important to take a closer look at the Tax Base and understand The Debt Bias as well as Non-profit Taxes
Tax Rates on Corporate Income
- Examining what the rankings illustrate, huge differences can be seen in effective tax rates across different countries
- In Europe, nations with the lowest tax rates are in Eastern countries, Cyprus and Ireland
- Tax reforms have occured over the course of 10 years, with CIT (Corporate income tax ) being relatively stable
- Germany is a high tax country but their tax base is broadening through anti-avoidance legislation
- It is worth consideration that Corporate income tax is only one location factor
- Important factors to note include market size, knowledge intensity, infrastructure, natural resources, factor costs, and if the nation is open to foreign investments
Analysing Declining Balance Depreciation
- If the interest rate is positive, Tax savings in early periods yield interest and tax savings have a value.
- Tax depreciation can have a major effect that changes the total tax base across all years as well as can change the optimality of choices.
- Accelerated depreciation can also be used as an investment incentive
- Accelerate depreciation may not be a great tool for stimulating investment during a downturn, Tax advantages of depreciation increase with increased Tax and discount rate
The Impact of Depreciation Schemes
- Depreciation allowances allocate acquisition costs to a number of periods based on useful life and this is fixed. This is also known as the tax base
- Example 1 from this perspective is designed so the Net Present Value, NPV is 0, but the NPV after income tax is > 0.
-In the example the real investment earns is based on the financial investment;
- The real investment has deductible allowances at the same rate T
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