Taxes and Business Decisions

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Questions and Answers

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'?

  • 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'?

  • 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?

<p>Tax revenues are the major source of government spending. (B)</p> Signup and view all the answers

Why is the international dimension of taxes becoming increasingly relevant?

<p>Because many transactions involve multiple countries. (C)</p> Signup and view all the answers

How can taxes influence a country's attractiveness as a business location?

<p>Taxes are a location factor and influence business decisions. (D)</p> Signup and view all the answers

What complicates the taxation of multinational firms in the global economy?

<p>The international integration and mobility of firms. (B)</p> Signup and view all the answers

What is a key characteristic that distinguishes multinational firms (MNEs) and makes taxing them complex?

<p>Complex global structure. (D)</p> Signup and view all the answers

Why is intra-firm trade significant in the context of taxing multinational firms?

<p>It involves highly specific goods, making it difficult to find adequate pricing. (D)</p> Signup and view all the answers

According to the content, what is a primary motivation for MNEs to re-allocate profits globally?

<p>To save on taxes. (C)</p> Signup and view all the answers

How does the Separate Entity Approach affect tax collection from multinational firms?

<p>It leads to each separate legal entity being taxed independently. (D)</p> Signup and view all the answers

How can international tax integration and firm mobility affect taxation?

<p>It makes taxation of multinational firms difficult. (D)</p> Signup and view all the answers

What is a key factor that might cause a mobile multinational enterprise (MNE) to shift its activity to another region?

<p>If taxes are too high. (B)</p> Signup and view all the answers

Why are countries concerned about the activities of multinational enterprises (MNEs)?

<p>MNEs have economic power similar to that of middle-income countries. (D)</p> Signup and view all the answers

According to the content, what can be considered a benefit provided by multinational enterprises (MNEs) to host countries?

<p>Knowledge spillover. (B)</p> Signup and view all the answers

What is the general policy consequence of strictly limiting tax discrimination against foreign investors?

<p>It prevents countries from taxing MNE's at lower rates than domestic firms. (B)</p> Signup and view all the answers

What is the intended goal of the OECD's work on concepts for a more coordinated approach to international taxation?

<p>To address tax avoidance and profit shifting. (C)</p> Signup and view all the answers

What characterizes tax evasion, as opposed to tax avoidance?

<p>It is illegal. (A)</p> Signup and view all the answers

What is a key difficulty distinguishing tax avoidance from legitimate tax planning?

<p>The degree to which the behavior is solely driven by tax means. (D)</p> Signup and view all the answers

In relation to corporate taxation, what does the 'tax base' refer to?

<p>The relevant income measure to apply the tax rate. (D)</p> Signup and view all the answers

What distinguishes financial accounting rules from tax accounting?

<p>Objectives differ between financial accounting and tax accounting. (B)</p> Signup and view all the answers

In terms of priorities, how do financial profits differ from taxable profits?

<p>Financial profits emphasize information content and firm performance. (C)</p> Signup and view all the answers

Which of the following is true regarding most countries' method of determining taxable profit?

<p>They adjust GAAP business profits to reflect tax objectives. (B)</p> Signup and view all the answers

Which of the following could cause differences in the tax base?

<p>The taxation of capital gains. (B)</p> Signup and view all the answers

Which of the following describes an effect of the depreciation scheme used?

<p>The timing effect of taxation changes the optimality of alternatives. (C)</p> Signup and view all the answers

Why are depreciation rules relevant for tax planning?

<p>Depreciation scheme determines timing of allowance. (D)</p> Signup and view all the answers

What generally happens if provisions are permitted to be formed under tax law?

<p>Tax savings arise from the earlier recognition of expenses. (A)</p> Signup and view all the answers

Symmetric treatment of profits and losses in taxation implies what?

<p>Sharing of investment risk between fiscal authorities and investors. (C)</p> Signup and view all the answers

Which of the following best describes how a loss carry-forward affects the deductibility of prior years if profits appear after losses?

<p>A decrease in taxation can occur in the periods after the loss. (C)</p> Signup and view all the answers

What factors make the value of loss carry-forward benefits uncertain?

<p>Expected future profits, loss period length and discount rate. (D)</p> Signup and view all the answers

According to the content, what is the primary purpose of allowing a notional interest deduction (NID)?

<p>To encourage equity financing. (B)</p> Signup and view all the answers

In what scenario is the tax benefit of notional interest deduction most pronounced?

<p>For investments earning a return similar to the fixed notional rate. (A)</p> Signup and view all the answers

According to the introduction to the topic, which of the following is true regarding separate legal entities of MNE?

<p>MNE's can allocate profits to different group entities. (B)</p> Signup and view all the answers

What distinguishes tax strategies, such as in innovation-heavy technology firms like Amazon or Google?

<p>They are completely legal. (C)</p> Signup and view all the answers

What best describes IP Box Regimes?

<p>Reduced rate on income from patents. (D)</p> Signup and view all the answers

What is a possible consequence of Innovation Tax Box Strategies?

<p>All of the options. (C)</p> Signup and view all the answers

The domestic tax rules on foreign income are also based on which international principle?

<p>Double tax treaties and domestic tax regulations. (C)</p> Signup and view all the answers

If a company is effectively connected to the territory of a country, that means:

<p>That the company is subjected to territory principle. (D)</p> Signup and view all the answers

Which situation can cause economic double taxation?

<p>The same income is earned through two different tax payers. (B)</p> Signup and view all the answers

What does the international standard for Double Taxation by OCED dictate?

<p>Allocation of taxing rights to source or residency. (D)</p> Signup and view all the answers

What is the most direct impact of multinational enterprises (MNEs) on national tax policies?

<p>They constrain the design of national tax policies. (A)</p> Signup and view all the answers

Why is it difficult to determine a fair price for transactions within multinational companies?

<p>These transactions often involve highly specific, unique goods or services. (A)</p> Signup and view all the answers

Which factor most directly motivates multinational enterprises (MNEs) to engage in international tax planning?

<p>To legally minimize their global tax liabilities. (D)</p> Signup and view all the answers

In the context of multinational enterprises (MNEs), what does the Separate Entity Approach entail?

<p>Treating each legal entity within the group as an independent entity for tax purposes. (D)</p> Signup and view all the answers

How does the mobility of multinational enterprises (MNEs) impact a country's tax policy options?

<p>It limits the ability of countries to aggressively tax MNEs due to the risk of businesses relocating. (C)</p> Signup and view all the answers

What constitutes a significant economic benefit that multinational enterprises (MNEs) can bring to a host country?

<p>Introduction of new technologies that leads to knowledge spillover. (A)</p> Signup and view all the answers

What is a key consideration when evaluating the impact of taxes on investment decisions?

<p>The after-tax rate of return relative to other investment options. (B)</p> Signup and view all the answers

Why might a country choose to offer tax incentives?

<p>To stimulate a specific type of economic activity. (B)</p> Signup and view all the answers

What factor has increased the relevance of international taxation?

<p>Growing international integration that involves firm mobility. (D)</p> Signup and view all the answers

What is a key factor determining a country's attractiveness for multinational firms?

<p>Its tax policies. (A)</p> Signup and view all the answers

What is the primary difference between financial and tax accounting?

<p>Financial accounting focuses on accurately presenting a company's financial performance. (A)</p> Signup and view all the answers

What is the primary aim when establishing accounting rules for financial profits?

<p>Providing relevant information and protecting investors. (D)</p> Signup and view all the answers

In most countries, what serves as the basis for calculating taxable profit?

<p>Financial accounting profits with certain adjustments. (D)</p> Signup and view all the answers

What can be the effect of differences in stock valuation methods (LIFO, FIFO, Weighted Average) on the tax base?

<p>They can lead to varying amounts of taxable profit. (D)</p> Signup and view all the answers

What is a key aspect regarding depreciation methods in tax planning?

<p>They can affect the timing of tax deductions. (D)</p> Signup and view all the answers

If tax law permits the formation of provisions, what usually results?

<p>Delayed tax payments due to the early recognition of expenses. (A)</p> Signup and view all the answers

What does symmetric treatment of profits and losses imply in taxation?

<p>Investors and tax authorities share investment risk. (A)</p> Signup and view all the answers

What factor would most likely reduce the actual value of a loss carry-forward?

<p>The possibility of future changes in tax law. (A)</p> Signup and view all the answers

What is the primary aim of allowing a Notional Interest Deduction (NID) for corporate equity?

<p>To eliminate tax discrimination between debt and equity financing. (B)</p> Signup and view all the answers

Which scenario provides the greatest tax benefit from a notional interest deduction?

<p>An investment with a return similar to the fixed notional interest rate. (D)</p> Signup and view all the answers

What is a key factor that contributes to the rise of tax competition among countries?

<p>The need to attract higher foreign investments. (D)</p> Signup and view all the answers

What limits the extent to which smaller countries can effectively compete with lower corporate tax rates?

<p>The need to generate government revenue. (C)</p> Signup and view all the answers

What is leading to a decrease in corporate income tax rates in some larger economies?

<p>Broadening of the tax base due to anti-avoidance measures. (C)</p> Signup and view all the answers

A key aspect that can result in double taxation or non-taxation?

<p>Cross-border transactions involving differing legal entities. (A)</p> Signup and view all the answers

What are the aims of coordinated international efforts to combat tax avoidance?

<p>To create a fairer tax distribution among jurisdictions. (C)</p> Signup and view all the answers

In transfer pricing which requirement limits setting prices?

<p>The arm's length principle. (C)</p> Signup and view all the answers

When is debt and equity are treated equally in taxation?

<p>When the fixed notional interest rate corresponds to the interest rates on loans. (A)</p> Signup and view all the answers

To be a special tax regime, what is the focus to be implemented in a country?

<p>With low tax rate cuts on mobile income. (A)</p> Signup and view all the answers

What does the benefit of IP box regimes further depends on?

<p>The scope of eligible IP assets. (D)</p> Signup and view all the answers

What is a result from Germany being a high tax country?

<p>Broadening of the tax base through antiavoidance legislation (D)</p> Signup and view all the answers

Why a tax payers arrange their business in order to minimize taxes?

<p>Taxpayers have the right to do so. (D)</p> Signup and view all the answers

According to the data is it possible to tax MNE at lower rates than domestic market?

<p>EUJ strictly limits tax discrimination between local and foreign investors (C)</p> Signup and view all the answers

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?

<p>Analyze alternative decision making with optimality. (D)</p> Signup and view all the answers

What is a type of a non-profit tax from the corporate level?

<p>The capital. (C)</p> Signup and view all the answers

When does taxation of capital is paid at the time?

<p>Taxation of capital/payroll can cause tax payments in absence of profits (D)</p> Signup and view all the answers

What is a purpose of allowing a notional interest deduction (NID)?

<p>To remove so called debt-equity Bias. (C)</p> Signup and view all the answers

A high equity capital can lead to

<p>High reductions of the tax base, regardless of the yielded return on investment. (C)</p> Signup and view all the answers

The belgium case showed that the notional interest deduction is heavily used for

<p>Cross-border tax planning activity (D)</p> Signup and view all the answers

Some multinational enterprises establish finance holdings in Belgium to:

<p>To benefit from deduction (C)</p> Signup and view all the answers

If NID/ACE narrows the tax base, puts pressure on governments to increase:

<p>The tax rate (B)</p> Signup and view all the answers

Revenues consequences, tax arbitrage and distributive issues are:

<p>The implementation of this regimes faces challenges (A)</p> Signup and view all the answers

Which of the following best characterizes the nature of a tax treaty?

<p>It is an agreement between two countries. (A)</p> Signup and view all the answers

What is the effect of double taxation?

<p>Discourages international investment (C)</p> Signup and view all the answers

An investor may have a large profit investment with a high percentage, however, when is that not an advantage?

<p>The more profitable an investment is, the smaller is the impact of deduction the allowance at the fixed rate (A)</p> Signup and view all the answers

What primary factor enables multinational enterprises (MNEs) to benefit from tax advantages worldwide?

<p>Their ability to allocate profits to group entities located in advantageous tax locations. (D)</p> Signup and view all the answers

What is the primary result of each separate legal entity within a multinational enterprise (MNE) being taxed individually?

<p>It can lead to either double taxation or complete non-taxation because the sections are not looked at as a whole. (D)</p> Signup and view all the answers

What is a key incentive for multinational enterprises (MNEs) to strategically re-allocate profits on a global scale?

<p>To take advantage of lower overall tax burdens and maximize after-tax profits. (A)</p> Signup and view all the answers

What factor might prompt a mobile multinational enterprise (MNE) to relocate its activities to a different country?

<p>Being subject to high tax rates relative to other potential locations. (D)</p> Signup and view all the answers

Why are countries increasingly focused on the tax policies and actions of multinational enterprises (MNEs)?

<p>Because some MNEs wield economic influence rivaling that of middle-income nations and concern over tax revenue. (B)</p> Signup and view all the answers

What impact does the European Court of Justice (ECJ) have on tax discrimination between local and foreign investors?

<p>It strictly restricts tax discrimination against foreign investors. (B)</p> Signup and view all the answers

How has the decline in corporate income tax rates in some larger economies affected tax competition?

<p>It has intensified tax competition among countries. (A)</p> Signup and view all the answers

What constitutes tax avoidance?

<p>Using legal means to minimize or eliminate tax liabilities. (D)</p> Signup and view all the answers

What is the primary goal when accounting rules are established for financial profits?

<p>Providing relevant and reliable information about the firm's financial information and performance. (D)</p> Signup and view all the answers

What is the starting point for determining taxable profit in most countries?

<p>Earnings reported according to financial accounting standards. (A)</p> Signup and view all the answers

What is a potential fiscal outcome when tax law allows for the formation of a provision, such as for warranty obligations?

<p>Tax savings from recognizing expenses earlier than would be allowed under financial accounting. (C)</p> Signup and view all the answers

What is meant by the symmetric tax treatment of profits and losses?

<p>The taxation of profits is consistent with the allowance of losses. (B)</p> Signup and view all the answers

What is the primary function of allowing a Notional Interest Deduction (NID)?

<p>To eliminate the bias toward debt financing. (A)</p> Signup and view all the answers

When is the benefit from allowing NID most notable?

<p>For more profitability that earn a return with a set rate. (C)</p> Signup and view all the answers

What are some key implementation challenges for special tax regimes?

<p>Revenue consequences, tax arbitrage, distributive issues, and EU Law. (D)</p> Signup and view all the answers

The generosity of the IP box system further depends on one of what factors?

<p>The types of IP eligible. (D)</p> Signup and view all the answers

What describes international dimensions?

<p>The transaction happened over different country or two. (A)</p> Signup and view all the answers

When is decision based on financial accounting standards not an advantage to an investor?

<p>When investment comes with very low profits. (D)</p> Signup and view all the answers

Which nations have the lowest tax rates in Europe, that allow for a high amount of tax revenue?

<p>Ireland (C)</p> Signup and view all the answers

The effective tax burdens depend on

<p>Tax rate and Tax base. (A)</p> Signup and view all the answers

Flashcards

Tax neutrality

Decision making unaffected by taxes

Tax distortion

Tax which discriminates between alternatives

Tax incentives

Intentionally introduced to stimulate certain behavior

International Transactions

Transactions involving more than one country

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MNE profit allocation

Allocating profits to group entities globally for tax advantages

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Separate entity taxation

Profit is taxed at each separate legal entity.

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Global profit shifting

Re-allocating profits globally in response to taxes

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Taxpayer right

The right to arrange business to minimize taxes

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Tax Evasion

Illegally reducing taxes

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Tax planning

Acceptable use of tax provisions to minimize tax burden

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Tax Avoidance

Behavior driven by tax means alone

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Effective place of management

Where the company is managed

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Corporate income tax

Tax on the profit of corporations

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Depreciation

Depreciation allowances that allocate acquisition costs.

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Depreciation scheme

Schemes that determine the timing of allowances

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Straight-line depreciation

Allocates the same depreciation each year.

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Declining-balance depreciation

Higher depreciation in the early years, subsequently decreasing

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Provisions

Designed to recognize the expense for obligations in future periods

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Symmetric treatment

Arrangement of tax where profits and losses are treated symmetrically

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Loss carry-back

Results in refund of prior year taxes if profit exists

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Tax loss compensation

Rules are relevant and significant for firms

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Non-profit taxes

Tax not based on profits earned

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Profit taxes

Related to the earnings of the company

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Capital/payroll tax

Cause payments even without profit, negative liquidity effects

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Corporate tax

Tax burden in the debt is smaller with debt financed investment

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Debt finacing advantage

Interest expenses are tax deductible but dividends are not

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Tax system with debt

System of most countries is distortionary in most countries with respect to financing investment

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Tax divends and interest

Countries tax dividends and interest receipts are the same rate and the discrimination of equity financing persists

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Additional debt incentive

An additional incentive is created to finance investments via debt

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Higher debt level

Debt levels are higher than world without taxes

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Financial limits

Limits via interest and debt

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Deduction of equity

Deduct the cost of equity financing (notional deduction)

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Synonym for Equity-ACE

Synonym for allowance of equity or allowance for growth and investment (AGI)

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Debt equity bias removal

Removed the debt equity bias, tax discrimination

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Tax discrimination

Tax discrimination of equity financing, stems from deductibility of interest

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Inveseted quity

Corporate must be fully aware

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Rely on tax incentives

Countries rely heavily reliance on tax incentives, correct a certain behaviour

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Notional Intrest deduction

A fixed return on equity deducted from the tax base

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Innovation box regimes

Income from intellectual property treated as reduced rates

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Shifting Tax burdens

Shift more tax tax payers to less mobile tax payers

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European Court of Justice

Limits tax discrimination between local and foreign investors

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Anti Tax legislation

Introduction of anti-avoidance legislation

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OECD and EU Commission

OECD and EU Commission concepts for more coordination

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Tax stratagies

Tax strategies, taxpayer are able to miniize taxes

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Tax Evasion

Illegal means to dodge taxes.

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Tax avoidance

Tax avoidance strategies

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Use tax provision

Acceptable tax avoidance, minimize tax burden

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Multination exploitation

Multinational firms can exploit rules for extremely low burdens

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Taxes combat loopholes

Tax law aims to combat low taxes by multination

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Tax differences with economic

Economic vs tax accounting, setting up reserves

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Tax rate impacts

Domestic tax rates impacts, also the effect of intrests (debt)

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Rate are important

Capital is a location factor, small countries need to make it favorable with rates

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Generate taxes

Countries are forced to generate least tax revenue, stability of rates

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Tax cut effects

Special tax regimes, recent rate cuts in high countries

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OECD globe Minimum

Global minimum tax of 15, larger corps

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tax rates

Effective tax burden

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Tax cut

No easy and no for capital

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Benefits in many locations

Separate approach leads to allocating profits to group entitites in these locations

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Minimizing rules

MNE = multinational enterprises which exploit

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Savings vs Equity

Equity vs Debt, no cross board consolidation of profits (tax savings)

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Equity debt firm structure

Equity and debt, separate firms into more access points

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Transfer changes

Transfer prices may be different per location

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Profits globe access

Allocation for profits (globally) to locations for better taxes for group access

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Investment choices tax

Investment choices, tax matter

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Rules globally

High tax and low tax countries need to know rules

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Always review taxes double

Double tax or no taxes can occur

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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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