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Cross-border aspects of corporate taxation
Laouici, Said ; Kotáb, Petr (advisor) ; Tuláček, Michal (referee)
- 1 - Cross-border aspects of corporate taxation Abstract This thesis addresses the key challenges, institutions, and current challenges in the cross- border taxation of concerns, which are better known as multinational companies. Multinational companies are business associations that must achieve the quality to be described as concerns, which are the focus of this thesis. The essential aspects in the cross-border taxation of a concern are the existence of double taxation or non-taxation, the transfer pricing and, finally, the new institutes that are aimed at reacting to the most recent and unsolved issues in this area. These are still numerous, but the efforts of countries and multinational organisations to tackle them are very strong. Specifically, this thesis deals with the essential instruments in the field of international taxation, such as double taxation treaties, transfer pricing, which can be described as traditional institutes, but also new institutes in the field of international taxation, which are BEPS action plans (Pillar I and Pillar II), MLI, EU directives, which compete with the basic and new instruments. The BEPS Action Plans and their impact are continuously reflected in each chapter of this thesis. The thesis also deals with tax competition, coordination, and harmonisation relationships...
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What Drives the Location of Profits: Examining the Behavior of Multinational Enterprises from Country-by-Country Reporting
Boukal, Tomáš ; Janský, Petr (advisor) ; Palanský, Miroslav (referee)
Multinational enterprises (MNEs) are increasingly using offshore financial centers to pay lower taxes on their profits. This behavior has distortive effects on the global economy, as the concentration of MNE activities resembles the global map of taxation. In this thesis, I exploit the OECD country-by-country reporting statistics to analyze the determinants behind the location of profits. I employ a gravity model and demonstrate that profits are highly sensitive to geographical proximity, with both physical and societal distance being significant factors. Furthermore, my findings suggest that, first, the existing literature's definition of financial secrecy lacks a conclusive role in attraction of extra profits, as its effects are likely to be already conveyed through taxation. Second, regarding the profits specifically located in offshore jurisdictions, a reverse gravity relationship exists, where multinationals are willing to incur extra costs to shift profits to more distant tax havens, revealing yet another geographical aspect of taxation.
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Global corporate tax reforms and how they might reduce profit shifting of multinational corporations
Pravda, Matúš ; Janský, Petr (advisor) ; Palanský, Miroslav (referee)
Global corporate tax reforms and how they might reduce profit shifting of multinational corporations Matúš Pravda 3rd January 2023 This study examines whether global corporate tax reforms might increase tax revenue which was reduced by the profit shifting of multinational corpora- tions. These reforms have been built on the minimum corporate tax rate and redistribution of undertaxed profits. Tax revenue gains of jurisdictions under all three tested global models show significant improvement in contrast to the status quo. Pillar II proposal would bring USD 198 billion in extra revenue, METR proposal USD 305 billion and the Tax deficit model USD 214 billion in 2017. However, significant differences are observed between geographical re- gions and income groups. North America and the EU are the largest recipients of extra tax revenue whereas Africa and Latin America & the Caribbean Islands are the smallest. Income group results show the same composition with high- income countries contributing by around three-quarters to the extra revenue gains. BEFIT Scenario 2 would result in USD 33 billion in extra tax revenue for the EU Member States, which is double the amount of Scenario 1. 1
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Tax avoidance by multinational corporations: An empirical analysis based on firm-level data
Godar, Sarah ; Janský, Petr (advisor) ; Barrios, Salvador (referee) ; Lejour, Arjan (referee) ; Weichenrieder, Alfons (referee)
Tax avoidance by multinational corporations An empirical analysis based on firm-level data Author: Sarah Godar Abstract In this thesis, I use confidential firm-level data from the Microdatabase Direct Investment (MiDi database) provided by the Deutsche Bundesbank to analyze tax avoidance by German MNCs. While such data has frequently been used in tax-avoidance research, it has yet to be employed to derive macro-level estimates of tax avoidance by Germany-based MNCs. My MiDi-based research includes an estimation of the scale of profit shifting by German affiliates of foreign MNCs and related tax-revenue losses (Chapter 1), as well as an investigation of the tax-haven use and distribution of profits and economic activity of MNCs headquartered in Germany (Chapter 2). Finally, in collaboration with several co-authors, I investigate relatively new micro data on the global tax payments and activities of multinational corporations, voluntarily published by individual MNCs following the implementation of the new CbCR standard (Chapter 3). I employ different methodological approaches depending on the quality of the data and the research focus of each chapter. In the first chapter, I employ a standard microeconometric approach to identify profit- shifting and estimate the semi-elasticities of MNCs' profits with...
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Country-by-Country Reporting Data and Profit Shifting of Banks
Bartoňová, Anna ; Janský, Petr (advisor) ; Želinský, Tomáš (referee)
Base erosion and profit shifting is a great concern of governments as well as the misalignment of the taxable income. With recently obtained country-by-country data we can address and measure the profit misalignment of financial institutions for 2014 - 2016. Using apportionment formula, we estimate the common consolidated corporate tax base (CCCTB) of each bank for every country specifically. The CCCTB then corresponds to profit created by real economic activity of a given bank in every country. We then observe the difference between CCCTB and actual taxable income, which determines the size of profit misalignment. We determine that around 30 % of world's income before tax is shifted to jurisdictions without accompanied economic activity. We find out that there is no time trend among the years. We conclude that large economies, such as United Kingdom, France, and Italy suffer more from profit misallocation, however, profit-havens Hong Kong, Ireland, or Luxembourg take advantage of the current system. We see that the Netherlands and Switzerland, which are usually considered to be tax havens, are with regard to bank industry, currently understating their income compared to the real economic activity in these countries.
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