IDEAS home Printed from https://ideas.repec.org/a/aiy/jnljtr/v5y2019i2p148-165.html
   My bibliography  Save this article

Improving the Efficiency of Anti-Tax Base Erosion Regimes through Tax Modelling

Author

Listed:
  • Liudmila V. Polezharova

Abstract

This article describes ways to enhance the efficiency of anti-tax base erosion measures aimed at preventing transnational corporations (TNCs) from shifting their profits from home countries to lower-tax jurisdictions. The research methodology comprises a set of mathematical models applied for a comprehensive analysis of tax planning methods used by TNCs and the counter-methods used by national governments. The models with postulated equilibrium consider tripartite financial structures (consisting of a parent company, a subsidiary in a loyal jurisdiction and an affiliate in an offshore jurisdiction) based on the principle of economic equilibrium in the distribution of incomes of different jurisdictions. The models are parametrized by using the data on tax regimes in different jurisdictions. The computational experiment focused on the tax regimes of a parent jurisdiction (Russian Federation), a typical loyal jurisdiction (Laos) and a typical offshore jurisdiction (British Virgin Islands). Thus, we considered the most important cases in international taxation regarding TNCs’ economic interests and the national welfare of the parent jurisdiction. The experiment tested the efficiency of different methods of fiscal regulation of international income and capital flows and showed that although the rules of controlled transactions are considered crucial for countering tax planning, they fail to bring the desired results in contemporary economic reality characterized by expanded international network of financial structures and accelerated growth of digital transactions. Based on our research findings, we formulated the following recommendations. The governments of parent jurisdictions are recommended to extend the rules of controlled transactions and controlled foreign corporations not only to offshores but also to loyal jurisdictions. For the Russian government, it may be effective to test and adopt the rules of secondary adjustments in combination with the rules of controlled transactions and controlled foreign corporations, to lower the rate of the tax on foreign dividends and to make the unreturned foreign dividends exempt from the additional tax should they be repatriated to Russia. Enhanced international cooperation in this sphere can maximize the efficiency of these measures.

Suggested Citation

  • Liudmila V. Polezharova, 2019. "Improving the Efficiency of Anti-Tax Base Erosion Regimes through Tax Modelling," Journal of Tax Reform, Graduate School of Economics and Management, Ural Federal University, vol. 5(2), pages 148-165.
    • Handle: RePEc:aiy:jnljtr:v:5:y:2019:i:2:p:148-165
    DOI: http://dx.doi.org/10.15826/jtr.2019.5.2.065
    as

    Download full text from publisher

    File URL: https://jtr.urfu.ru/fileadmin/user_upload/site_15907/main/Polezharova.pdf
    Download Restriction: no
    File URL: https://libkey.io/http://dx.doi.org/10.15826/jtr.2019.5.2.065?utm_source=ideas
    LibKey link: if access is restricted and if your library uses this service, LibKey will redirect you to where you can use your library subscription to access this item
    ---><---

    References listed on IDEAS

    as
    1. Stéphane Sorbe & Åsa Johansson, 2017. "International tax planning and fixed investment," OECD Economics Department Working Papers 1361, OECD Publishing.
    2. John Whalley, 2001. "Puzzles Over International Taxation of Cross Border Flows of Capital Income," NBER Working Papers 8662, National Bureau of Economic Research, Inc.
    3. Harry Grubert, 2003. "The Tax Burden on Cross-Border Investment: Company Strategies and Country Responses," CESifo Working Paper Series 964, CESifo.
    Full references (including those not matched with items on IDEAS)

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Pierre Salmon, 2003. "The assignment of powers in an open-ended European Union," Post-Print hal-00445601, HAL.
    2. Abdullah Kumas & Daniel L. Millimet, 2018. "Reassessing the effects of bilateral tax treaties on US FDI activity," Journal of Economics and Finance, Springer;Academy of Economics and Finance, vol. 42(3), pages 451-470, July.
    3. Ang, James & Knill, April & Mauck, Nathan, 2017. "Cross-border opportunity sets: An international empirical study based on ownership types," Global Finance Journal, Elsevier, vol. 33(C), pages 1-26.
    4. Buettner, Thiess & Overesch, Michael & Schreiber, Ulrich & Wamser, Georg, 2009. "Taxation and capital structure choice--Evidence from a panel of German multinationals," Economics Letters, Elsevier, vol. 105(3), pages 309-311, December.
    5. Ali-Yrkkö, Jyrki & Rouvinen, Petri, 2013. "Implications of Value Creation and Capture in Global Value Chains – Lessons from 39 Grassroots Cases," ETLA Reports 16, The Research Institute of the Finnish Economy.
    6. Balázs Égert, 2021. "Investment in OECD Countries: a Primer," Comparative Economic Studies, Palgrave Macmillan;Association for Comparative Economic Studies, vol. 63(2), pages 200-223, June.
    7. Ana Agundez-Garcia, 2006. "The Delineation and Apportionment of an EU Consolidated Tax Base for Multi-jurisdictional Corporate Income Taxation: a Review of Issues and Options," Taxation Papers 9, Directorate General Taxation and Customs Union, European Commission, revised Oct 2006.
    8. Kartikeya Singh & Cody Kallen & Aparna Mathur, 2020. "Substance Requirements in the International Taxation of Intangible Capital: A Double-edged Sword?," Public Finance Review, , vol. 48(2), pages 139-177, March.
    9. Rixen, Thomas & Rohlfing, Ingo, 2020. "The Institutional Choice of Bilateralism and Multilateralism in International Trade and Taxation," SocArXiv uwge8, Center for Open Science.
    10. Azevedo, Alcino & Pereira, Paulo J. & Rodrigues, Artur, 2021. "Optimal timing and capacity choice with taxes and subsidies under uncertainty," Omega, Elsevier, vol. 102(C).
    11. Ang, James & Knill, April & Mauck, Nathan, 2014. "Investment Opportunity Sets of Real Assets: An International Empirical Study Based on Ownership Types," MPRA Paper 53359, University Library of Munich, Germany.
    12. Rixen, Thomas, 2008. "The institutional Design of international double Taxation Avoidance," MPRA Paper 8322, University Library of Munich, Germany.
    13. Cooper, Maggie & Nguyen, Quyen T.K., 2019. "Understanding the interaction of motivation and opportunity for tax planning inside US multinationals: A qualitative study," Journal of World Business, Elsevier, vol. 54(6), pages 1-1.
    14. Maria Borga & Perla Ibarlucea Flores & Monika Sztajerowska, 2020. "Drivers of divestment decisions of multinational enterprises - A cross-country firm-level perspective," OECD Working Papers on International Investment 2019/03, OECD Publishing.
    15. Rosanne Altshuler & Harry Grubert, 2004. "Taxpayer Responses to Competitive Tax Policies and Tax Policy Responses to Competitive Taxpayers: Recent Evidence," Departmental Working Papers 200406, Rutgers University, Department of Economics.
    16. Gaëtan Nicodème, 2002. "Sector and size effects on effective corporate taxation," European Economy - Economic Papers 2008 - 2015 175, Directorate General Economic and Financial Affairs (DG ECFIN), European Commission.
    17. Brem Markus, 2005. "Globalization, Multinationals and Tax Base Allocation: Advance Pricing Agreements as Shifts in International Taxation?," IIMA Working Papers WP2005-12-01, Indian Institute of Management Ahmedabad, Research and Publication Department.
    18. Cooper, Maggie & Nguyen, Quyen T.K., 2020. "Multinational enterprises and corporate tax planning: A review of literature and suggestions for a future research agenda," International Business Review, Elsevier, vol. 29(3).
    19. Michael Daly, 2006. "WTO Rules on Direct Taxation," The World Economy, Wiley Blackwell, vol. 29(5), pages 527-557, May.

    More about this item

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:aiy:jnljtr:v:5:y:2019:i:2:p:148-165. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Natalia Starodubets (email available below). General contact details of provider: https://edirc.repec.org/data/seurfru.html .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.