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Odhad přesunu zisků po zavedení pravidel GloBE
Chrástová, Leona
The diploma thesis deals with the estimation of profit shifting after the in-troduction of GloBE rules. These rules, issued by the OECD, should ensure fairer taxation of the income of multinational companies and reduce base erosion and profit shifting. The aim of this work was to determinate changes in taxation of multinational corporations after the introduction of new rules for international taxation. To achieve the goal, the procedures described in Pillar 2 were applied to data from the Orbis database in the empirical part of this work. The empirical part also considered two assumptions for the collection of top-up tax, i.e. collection at the level of the jurisdiction of headquarter parent company and collection at the level of the jurisdiction of member entities. The results show that the OECD and EU jurisdictions could receive up to EUR 270 billion from this initiative. Large econo-mies such as the United States of America and Great Britain would receive the highest returns from this initiative. However, the largest percentage changes in tax revenues would be achieved by states known as tax havens, i.e. Luxembourg, Ireland and Latvia.
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Profit shifting of European banks: Evidence from Global Reporting Initiative data
Sůva, Daniel ; Janský, Petr (advisor) ; Pavlova, Alena (referee)
This thesis investigates the profit shifting practices of European banks using country-by-country reporting data. The main contribution is the first use of Global Reporting Initiative reports by hand-collecting a sample of six banks. The thesis estimates the banks' effective tax rates in two ways, highlighting the advantages and limitations of each method. Additionally, the study com- pares the economic activity, employees, and tangible assets in tax havens and estimates multiple models to estimate the amount of shifted profits into tax havens. The analysis finds no significant connection between the effective tax rate of jurisdiction and booked profits, which is in contrast to a large body of existing literature. It concludes that the sampled banks do not systematically use tax havens but confirms a positive relationship between a bank's size and its participation in profit shifting. The thesis also highlights the correlation between tax transparency and lower tax avoidance among the sampled banks, which is in line with the hypothesis that increased transparency can increase tax revenue.
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Daňové raje a dopady na štátny rozpočet
Bírošík, Roman
This diploma thesis deals with the erosion of the tax base and profit shifting to countries known as tax havens. It describes the techniques that allow use of tax havens and thus reduce tax liability. The empirical part of the thesis examines profit shifting of Czech multinational companies to tax havens through internal debt.
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Tax avoidance by multinational corporations: evidence from new data
Vinogradov, Alex ; Janský, Petr (advisor) ; Palanský, Miroslav (referee)
The CbCR data published based on OECD's Action 13 of the 2015 Final Report represents the best macroeconomic CbCR dataset today. This thesis analyzes its second year of published data (2017), calculates historical ETRs and builds on top of the semi-elasticity model of profits with specifications successfully estimated on the 2016 data, with the use of OLS models, WLS models, which enabled the retention of the maximum amount of data and the unique use of Country Level Premium as a predictor proved itself as a better predictor than the alternative GDP per capita. The estimated semi-elasticity from the best model is then used to calculate the amount of shifted profits. JEL Classification B10, F01, F02, F15, F40, C21 Keywords BEPS, ETR, historical ETR, Country Risk Pre- mium Title Tax avoidance by multinational corporations: evidence from new data Abstrakt CbCR data jsou publikovaná v rámci akčniho bodu 13 Závěrečného reportu OECD a představují dnes ten nejlepší dataset ekonomickích dat, reportovaních po jednotlivích zemích. Tato diplomová práce analyzuje druhý ročnik techto data - pro rok 2017, spočitá efetivní daňovou míru a modeluje semi-elasticitu profitu pomocí OLS a poté WLS, terý umožni využít maximum pozorování z datasetu a zahrne riziková premia pro jednotlivé země jako preditor. Nejlepší...
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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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Determinants of the Demand for Tax Haven Operations: Empirical Evidence from the Czech Republic
Burianová, Markéta ; Janský, Petr (advisor) ; Švarcová, Natálie (referee)
The aim of this thesis is to explore the firm-specific determinants of the demand for tax haven operations by Czech firms. Our objective is to better understand the firms' incentives for tax haven use, and furthermore whether there exists cross-haven heterogeneity in those incentives. The thesis examines the firms' tax haven investment behaviour by analysing firm-level data for 15,530 Czech firms for year 2013. To the extent of our knowledge, this has been the first research of its kind devoted to Czech firms. The evidence suggests that larger, more profitable firms with larger international presence are most likely to use tax havens. The analysis also indicates that higher firm indebtedness is associated with greater likelihood of establishing tax haven operations. This would suggest Czech firms engage in profit shifting through the use of debt financing. Furthermore, service firms were found to be more likely to use tax havens than manufacturing firms. This contrasts with previous research where R&D intensity was a leading indicator of tax haven use. Additionally, we found significant cross-haven heterogeneity in the determinants, particularly in the sector-specific characteristics. In our sample, service firms favoured Cyprus and the Netherlands, while manufacturing firms preferred Luxembourg...
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Corruption, Tax Abuse, and Financial Secrecy
Palanský, Miroslav ; Janský, Petr (advisor) ; Riedel, Nadine (referee) ; Zucman, Gabriel (referee) ; Johannesen, Niels (referee)
Corruption, Tax Abuse, and Financial Secrecy PhD Dissertation, Miroslav Palanský, IES CUNI, 2020 Abstract This dissertation is composed of three papers that focus on different aspects of the relationship between the public sector and individuals who do not comply with the norms and regulations set by the government. I classify the ways in which individuals do so into two categories - corruption and tax abuse. Corruption, defined as the abuse of entrusted power for private gain, results in individuals obtaining more benefits from the public sector than is intended. Tax abuse, on the other hand, is defined as contributing less to the public sector than is intended. The last chapter of the dissertation focuses on financial secrecy, which I argue is the key facilitator of the two channels. In Chapter 2, I show that companies that donate money to Czech political parties subsequently report abnormally high profits, pointing to preferential treatment that these firms enjoy as a result of their political connections: I conservatively estimate that the connected firms outperform their non-connected but otherwise similar competitors by 8 to 12% following the establishment of the connection, which is a higher effect than found previously for more developed economies. Importantly, however, I find that the effect...
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Profit shifting activities of multinational banks in Ghana
Ali, Issifu
Ali I. Profit Shifting Activities of Multinational Banks in Ghana. Bachelor Thesis. Mendel University in Brno, 2019 This study examined the evidence of profit shifting activities of multinational banks, measure the magnitude of profit shifting of foreign banks in Ghana and lastly to find out whether the financing decision by multinationals can be a mechanism of profit shifting. The study covered 10year accounting period from 2006 to 2015 and took into consideration multinational banks operating in Ghana. For this study 13 banks were chosen as a sample size. In all, a total of 130 data set were used. The variables employed for the study was Profit before tax, leverage/debt ratio which represents the dependent variables and the independent variables consists of Differential Tax Rate, Total Assets, Other Income, Personnel Cost, Fixed Assets and macroeconomic variables (Economic Growth, GDP rate, and Corruption Index). From this study, a panel data regression was conducted, and the findings indicated there was evidence of profit shifting where the results of TDIF showed a negative coefficient of 1.823 and was significant on PBT. In addition, the macroeconomic variable namely GDP and GDPR added to the model also showed a negative coefficient of 1.803 and 2.600 respectively. The results obtained using leverage as a dependent variable also proved the coefficient of TDIF was negative (0.106) indicating evidence of profit shifting. In the second mode, CPI was added and the evidence found a negative coefficient of 0.0902. A negative coefficient of 0.1 and 0.0874 was evident after adding GDP and GDPR respectively proving a profit shift. In view of the discoveries, the examination suggests that Ghana as a member of the OECD should stick to the tenets and rules of the OECD action plan which helps to fight profit shifting. Ghana Revenue Authority should tighten the rules in regulating multinationals, especially the transfer pricing rules. Again the Ghana Revenue Authority (GRA) should improve their Administrative tax system especially in the area of multinational taxing. Tax authorities should be well resourced and educated to equip them with the necessary skills and technical knowledge needed to understand the approach used methods used by these multinationals banks to shift their profit and avoid paying taxes.
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Tax competition: strategic tax rate lowering and expected impact of US 2017 reform on other countries
Hamráková, Júlia ; Janský, Petr (advisor) ; Hájek, Jan (referee)
This thesis deals with an international corporate income tax competition with focus on corporate income tax rate spillovers from the past tax cuts in the USA. The main research question we seek the answer to is: "Do countries follow the USA in the corporate income tax rate setting?" Empirical models were evalu- ated using GMM model for the panel data. Our results confirm the existence of the tax rate spillovers, however, do not prove solid leadership of the USA in the tax rate setting. We found that countries which are geographically closer to the USA and OECD jurisdictions are more likely to follow the USA in the tax rate policy changes. Our research is unique extension to the previous literature dealing with this topic as it uses not only the weighted world corporate income tax rate in the model, but also the corporate income tax rate of the USA and therefore allows us to see the effect of the past tax cuts in the USA for other countries. The results of our work can serve as a lead for examining the impact of the US tax rate cut in 2017. JEL Classification F12, F21, F23, H25 Keywords tax competition, corporate income tax rate, tax spillovers, profit shifting Title Tax competition: strategic tax rate lowering and expected impact of US 2017 reform on other countries Author's e-mail...
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The Scale of Corporate Profit Shifting out of the United States
Stárek, Martin ; Janský, Petr (advisor) ; Vacek, Pavel (referee)
There is a large body of literature indicating that profits are shifted into countries with better conditions, i.e. lower tax rates. It was showed that the problem is nonlinear. However, precise estimates are missing in the available literature. In this thesis we improved the precision by allowing for nonlinearity, time-variant tax semi-elasticity of profits and financial secrecy is a driver of the profit shifting. We showed that all three elements of the estimation are very important. Our analysis suggests that the profit shifting problem started at the turn of millennium and increases since, with some temporal drops. The highest amount of profit shifted out of the United States was almost 300 billion of U.S. dollars with the consequent revenue loss of 62.3 billion of U.S. dolars.
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