Preview

Assignment

Powerful Essays
Open Document
Open Document
17007 Words
Grammar
Grammar
Plagiarism
Plagiarism
Writing
Writing
Score
Score
Assignment
Transfer pricing, tax havens and global governance

Ganapati Bhat

Bonn 2009

Discussion Paper / Deutsches Institut für Entwicklungspolitik ISSN 1860-0441

Bhat, Ganapati: Transfer pricing, tax havens and global governance / Ganapati Bhat. – Bonn : DIE, 2009. – Discussion Paper / Deutsches Institut für Entwicklungspolitik ; 7/2009) ISBN 978-3-88985-455-1

Ganapati Bhat is an officer of the Indian Revenue Service, presently working in the Directorate of Transfer Pricing of the Government of India. His research interests are Multinational Corporations, Foreign Direct Investment and Transfer Pricing. E-mail: gr.bhat@yahoo.co.in

© Deutsches Institut für Entwicklungspolitik gGmbH Tulpenfeld 6, 53113 Bonn +49 (0)228 94927-0 +49 (0)228 94927-130 E-Mail: die@die-gdi.de http://www.die-gdi.de

This study has been prepared as part of the Managing Global Governance Programme, an initiative of the German Ministry for Economic Cooperation and Development (BMZ), implemented jointly by the German Development Institute (DIE) and Capacity Building International Germany (InWent) in 2008. The author would like to acknowledge with gratitude the valuable suggestions and guidance of Thomas Fues of DIE, Quentin Dupriez and Mike Pfister of the United Nations Conference on Trade and Development (UNCTAD), Nagesh Kumar of Research and Information System for Developing Countries (RIS) and Khan Masood of Jamia Milia Islamia. The author is also grateful to Manoranjan Hota, Sachin Chaturvedi, S.K. Mohanty and Ram Singh for their help and encouragement. The views expressed reflect the personal opinion of the author and cannot in any way be ascribed to the Income Tax Department of the Government of India or to other institutions and persons referred to above.

Foreword

Tax-motivated transfer pricing has attracted world attention owing to the existence of low-tax jurisdictions and the volume of the activities of multinational corporations (MNCs). MNCs have many instruments



Bibliography: Devereux, Michael P. / Ben Lockwood / Michela Redoano (2008): Do countries compete over corporate tax rates?, in: Journal of Public Economics 92 (5–6), 1210-1235 – (2006): Do tax havens divert economic activity?, in: Economics Letters 90 (2), 219–224 Desai, Mihir A. / Fritz C. Foley / James R. Hines Jr. (2005): Do tax havens divert economic activity? Social Sciences Research Network (Electronic Paper Collection); online: http://ssrn.com/abstract=891211 (accessed 28 May 2008) Demirguc-Kunt, A Cravens, Karen S. (1997): Examining the role of transfer pricing as a strategy for multinational firms, in: International Business Review 6 (2), 127–145 Clausing, Kimberly A Bucovetsky, Sam / John Douglas Wilson (1991): Tax competition with two tax instruments, in: Regional Science and Urban Economics 21 (3), 333–350 Browning, Lynnley (2008): Seeking tax cheats, U.S – (2008): The history of PATA and its effect on pricing arrangements and mutual agreement procedures, in: Journal of International Accounting, Auditing and Taxation 17 (1), 31–50 Borkowski, Susan C Bartelsmann, Eric J. / Roel M. W. J. Beetsma (2001): Why pay more? Corporate tax avoidance through transfer pricing in OECD countries, in: Journal of Public Economics 87 (9–10), 2225–2252 Baker, Raymond W G7 (1999): Statement of finance ministers and central bank governors, September 25, 1999, Washington, DC; online: http://www.g20.org/G20/webapp/publicEN/publication/further/doc/19990925_g7_statement_ about_g20 (accessed 1 June 2008) Foley, Fritz C Elitzur, Ramy / Jack Mintz (1996): Transfer pricing rules and corporate tax competition, in: Journal of Public Economics 60 (3), 401– 422 Economist (2000): Globalization and tax: the world’s view of multinationals, 29 Jan Goolsbee, Austan / Edward L. Maydew (2000): Coveting thy neighbor’s manufacturing: the dilemma of state income apportionment, in: Journal of Public Economics 75 (1), 125–143 Gordon, Roger H Sørensen, Peter Birch (2004): Company tax reform in the European Union, in: International Tax and Public Finance 11 (1), 91–115 US Treasury (2008): Report on foreign holdings of U.S

You May Also Find These Documents Helpful

  • Better Essays

    Cited: Smith, E., Harmelink, P., & Hasselback, J. (2014). CCH Federal Taxation: Comprehensive Topics 2015. [VitalSource Bookshelf version].…

    • 2389 Words
    • 9 Pages
    Better Essays
  • Powerful Essays

    Solution Manuel

    • 10315 Words
    • 42 Pages

    CHAPTER 9 TAXATION OF INTERNATIONAL TRANSACTIONS SOLUTIONS TO PROBLEM MATERIALS | | | | |Status: | Q/P | |Question/ |Learning | | |Present |in Prior | |Problem |Objective |Topic | |Edition |Edition | | | | | | | | | | | 1 LO 1 Worldwide income Unchanged 1 2 LO 1 Worldwide income Unchanged 2 3 LO 2 Tax treaties New 4 LO 3 Sourcing of income New 5 LO 3 Sourcing of income Unchanged 5 6 LO 3 Section 482 Unchanged 6 7 LO 4 Foreign currency New 8 LO 4 QBUs New 9 LO 4 Section 988 gain or loss New 10 LO 5 Section 367 New 11 LO 5 Foreign Corporation New 12 LO 5 CFC status New 13 LO 5 CFC status Unchanged 13 14 LO 5 Definition of CFC Unchanged 14 15 LO 5 Foreign tax credit limitation New 16 LO 5 Foreign tax credit or deduction New 17 LO 5 Section 902 credit Modified 16 18 LO 5 Foreign tax credit (FTC) issues Unchanged 18 19 LO 5 FTC baskets of income New 20 LO 6 Inbound taxation New 21 LO 3, 6 U.S. taxation of foreign corporation Modified 21 22 LO 3, 6 Inbound versus outbound activities Unchanged 22 23 LO 1, 3, 5 Worldwide taxation and the FTC Modified 23 24 LO 4, 5 Deferral of foreign income Modified 24 *25 LO 3 Income sourcing Modified 25 26 LO 3 Income sourcing Modified 26 *27 LO 3 Income sourcing Modified 27 *28 LO 3, 6 Income sourcing Modified 28…

    • 10315 Words
    • 42 Pages
    Powerful Essays
  • Powerful Essays

    Bibliography: Adams, C. (1993). For Good and Evil: The Impact of Taxes on the Course of Civilization. Landham, MD, USA: Madison Books.…

    • 2471 Words
    • 10 Pages
    Powerful Essays
  • Powerful Essays

    Offshore Tax Havens

    • 1699 Words
    • 5 Pages

    Offshore tax havens are a tax-avoiding loophole that sends money over seas where there is no or little tax. This has become the go to move of some of the top corporations of the United States as these companies are costing the U.S over one hundred fifty billion dollars of revenue each year. (1) Last year alone it was concluded that the top fifteen multinational companies held $776 billion dollars offshore in various subsidiaries that totaled around 859. With that in mind, the top one hundred companies held about 1.7 trillion dollars offshore. (2) Corporate taxes in the U.S. are taxed at a rate of thirty five percent, where on average the offshore tax havens are taxed at a mere 6.9 percent. (2) These offshore accounts can be seen as “nominal, hyper-portable, multi-jurisdictional, often quite temporary locations of networks of legal and quasi legal entities and arrangements that manage and control private wealth”. (3) Tax havens have become a major issue in the U.S. as the top corporations of the country show no sign of slowing in their games of tax avoidance schemes.…

    • 1699 Words
    • 5 Pages
    Powerful Essays
  • Powerful Essays

    Patriot Act

    • 14268 Words
    • 58 Pages

    Candidate for the LL.M. Degree in International Taxation & Financial Services, Walter H. & Dorothy B. Diamond Graduate International Tax Program Thomas Jefferson School of Law…

    • 14268 Words
    • 58 Pages
    Powerful Essays
  • Powerful Essays

    Cited: Foundation, T. (2013, December 18). Tax Foundation. Retrieved March 28, 2015, from http://taxfoundation.org: http://taxfoundation.org/article/oecd-corporate-income-tax-rates-1981-2013…

    • 2246 Words
    • 23 Pages
    Powerful Essays
  • Better Essays

    f(x1, x2) = x1 + x2. Now this is Cobb-Douglas if the function has the form f(x1,x2) = Ax^a1 x^b2, and provides us the utility function (Varian, 2010) and the graph shown in fig 3. For the production formula it would be Q=AK^ αL^β (Renshaw, 2009)as you can see both formulas are remarkably similar, as they both steam from the original theorem. So if we set A=10 and α= β=0.5, we get Q=10K^0.5L^0.5 now if we fix capital to say 49, just for the short run, we get Q=10(49)^0.5L^0.5 which we can rearrange so that we get Q=70L^0.5. Now to find the average product of labour or APL we divide Q by L, Q/L. So using Q=70L^0.5 we get 70L^0.5/L= 70L^0.5 (Renshaw, 2009). Obviously this is all in the short term, but if we wish to find it with terms of market value we would time the equation by the price so say our good is p=100 we get, Q=P(10K^0.5L^0.5) so with ours we get Q=100(10K^0.5L^0.5)=1000K^0.5^0.5 giving us the firms total revenue in term of sale price and labour and capital the firm hires.…

    • 1850 Words
    • 8 Pages
    Better Essays
  • Powerful Essays

    Tax Planning for U.S. Investors

    • 24469 Words
    • 116 Pages

    Permanent Establishment as Holding 16 2.4.5 European Company (Societas Europaea) 16 2.5 Functional Classification 17 2.5.1 Management Holding Company 17 2.5.2 Finance Holding Company 17 2.5.3 Euro-Holding Company 18 2.5.4 Country Holding Company 19 2.5.5 Mixed Holding Company 19 2.6 Concluding Remarks 3 19 TAX PLANNING WITH HOLDING COMPANIES 20 3.1 Features of a Holding Company Jurisdiction 20 3.2 The Tax Planning Model 22 3.2.1 Benchmarking 22 3.2.2 Analysis 23 3.2.3 Strategy 23 3.2.4 Implementation 24 3.2.5 Compliance 24 3.3 Tax Planning Tools 24 3.3.1 Participation Exemption Shopping 24 3.3.2 Capital Gains Exemption Shopping 24 3.3.3 Treaty Shopping 25 3.3.4 Treaty Exemption Shopping/Deferral Shopping 26 3.3.5 Credit Mix Shopping 26 3.3.6 Rule Shopping 26 3.3.7 Deduction Shopping 27 3.3.8 Cross-border Group Relief Shopping 27 3.3.9 Tax Rate Shopping 28 3.4 Concluding Remarks 4 TAX HAVENS AND TAX COMPETITION 28 29 4.1 Characteristics of Tax…

    • 24469 Words
    • 116 Pages
    Powerful Essays
  • Satisfactory Essays

    Many international businesses transfer their operations like production and services to the countries where the tax rates are lower, compared to their mother country, where the parent company has its headquarters. According to OECD Statistics, that researchers have performed, there is a remarkable growth in the transfer of all these intangible assets from 13 percent to 37 percent in a period of 28 years, from 1983 to 2011.…

    • 443 Words
    • 2 Pages
    Satisfactory Essays
  • Good Essays

    To accomplish this review, I will bring together disparate literatures on the economics of tax havens, the legal history of international taxation, and the research on the politics underlying treaty and customary laws. Even after laying aside this philosophical question of justice, the problem Piketty identifies poses a challenge to disciplines beyond economics, a reality Piketty himself notes when tracing his book’s…

    • 774 Words
    • 4 Pages
    Good Essays
  • Powerful Essays

    mr.andrew

    • 40072 Words
    • 170 Pages

    • Are there aspects of the current tax system which are particularly distorting? 3. Our work is based on extensive written evidence, which is remarkable for the degree of common ground on basic principles. It is also based on two sessions of oral evidence.…

    • 40072 Words
    • 170 Pages
    Powerful Essays
  • Powerful Essays

    1994 Mexican Currency Crisis

    • 4579 Words
    • 19 Pages

    McQuillan, L.J. & Montgomery, P.C. (1999). The International Monetary Fund: Financial Medic to the World? Hoover Institution Press Publication; United States of America.…

    • 4579 Words
    • 19 Pages
    Powerful Essays
  • Better Essays

    Dunbar, C. (1984, October). The new income tax. The Quarterly Journal of Economics, Retrieved from http://www.jstor.org/stable/1883633.…

    • 1436 Words
    • 6 Pages
    Better Essays
  • Good Essays

    Tax Avoidance

    • 486 Words
    • 2 Pages

    There is an increasing amount report claimed that the UK government losing money from tax avoidance. The BBC reported that some multinational companies use tax avoidance strategy to decrease the tax. It seems like these companies are lack of corporate social responsibility. However, tax avoidance does not equal to tax evasion. Some individuals assert that the government should publish a new policy to stop tax avoidance. While many others argue that it is blameless economic activity in the economic market to reduce the tax. Personally, I am in favor of the latter view. This essay will give the background of tax avoidance and discuss whether the government should ban tax avoidance.…

    • 486 Words
    • 2 Pages
    Good Essays
  • Powerful Essays

    Transfer Pricing

    • 13608 Words
    • 55 Pages

    Transfer pricing, for tax purposes, is the pricing of inter Company transactions that take place between affiliated businesses. The transfer pricing process determines the amount of income that each party earns from that transaction. Taxpayers and the taxing authorities focus exclusively on related-party transactions, which are termed controlled transactions, and have no direct impact on independent-party transactions, which are termed uncontrolled transactions. Transactions, in this context, are determined broadly, and include sales, licensing, leasing, services, and interest…

    • 13608 Words
    • 55 Pages
    Powerful Essays