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Misalignment of Profits and Economic Activity by Multinational Enterprises
Cimpová, Dominika ; Janský, Petr (advisor) ; Palanský, Miroslav (referee)
This thesis analyses the profit shifting behaviour of U.S. multinational companies using panel data set over the period 1983 - 2015. The main objective of the thesis is to com- pute the extent of misalignment between reported profit and real economic activity and consequential revenue losses caused by profit shifting and to estimate the effect of tax rates on profit shifting behaviour. Using country-level aggregated data published by the Bureau of Economic Analysis I found a substantially increasing trend in the misaligned profit reaching 540 bn US$ in 2015 which is accompanied with tax revenue losses 190 bn US$ in missing profit countries. Majority of the misaligned profit is reported in a small number of jurisdictions with near zero tax rates such as Netherlands, Ireland and Luxem- bourg. Additionally, I found a significant negative effect of tax rate on misalignment in the recent years, however, only negligible effect at the beginning of the examined period. Results suggest that 1% increase in the statutory tax rate can cause 2.5% growth in the magnitude of misalignment. My findings are consistent with the existing literature. Ac- cording to the analysis it can be concluded that despite numerous attempts for prevention of profit shifting, it is becoming more serious problem than ever before.
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Misalignment of Profits and Economic Activity by Multinational Enterprises
Cimpová, Dominika ; Janský, Petr (advisor) ; Palanský, Miroslav (referee)
This thesis analyses the profit shifting behaviour of U.S. multinational companies using panel data set over the period 1983 - 2015. The main objective of the thesis is to com- pute the extent of misalignment between reported profit and real economic activity and consequential revenue losses caused by profit shifting and to estimate the effect of tax rates on profit shifting behaviour. Using country-level aggregated data published by the Bureau of Economic Analysis I found a substantially increasing trend in the misaligned profit reaching 540 bn US$ in 2015 which is accompanied with tax revenue losses 190 bn US$ in missing profit countries. Majority of the misaligned profit is reported in a small number of jurisdictions with near zero tax rates such as Netherlands, Ireland and Luxem- bourg. Additionally, I found a significant negative effect of tax rate on misalignment in the recent years, however, only negligible effect at the beginning of the examined period. Results suggest that 1% increase in the statutory tax rate can cause 2.5% growth in the magnitude of misalignment. My findings are consistent with the existing literature. Ac- cording to the analysis it can be concluded that despite numerous attempts for prevention of profit shifting, it is becoming more serious problem than ever before.
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International tax planning and tax evasion
Benková, Eva ; Finardi, Savina (advisor) ; Vančurová, Alena (referee)
In my work, I would like to address the issue of tax evasion in connection with cross-border transactions. I would like to explain the basic concepts and fundamental principles of taxation of income taxes in the EU or other countries. I will describe some of the regulations that relate to the topic, so that even the common nominator get an idea of their content. These include the "Convention for the avoidance of double taxation" or "Law on Money Laundering." It will also affect issues of permanent establishments and taxation, transfer pricing issues. Vouchers for abuse of rights transformations - specifically misuse mergers. In this work will be description of tax evasion, from the perspective of Czech law and EU law and international law. The work culminates examples of tax fraud with reference to individual judgments.
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