Browsing by Subject "Verrechnungspreis"

Now showing 1 - 3 of 3

Efficiency of selected fiscal policy instruments
(2017) Dekker, Vincent; Dwenger, Nadja
The thesis at hand intends to contribute to the understanding of behavioural responses to taxation by dedicating each chapter to the analysis of a different fiscal policy instrument. Chapter 2 focusses on the individual tax system in the Netherlands that exhibits tax brackets, as opposed to a smooth progressive tax system. The aim is to uncover the extent of behavioural responses to the kinks in the budget set that are created by the non-linear increases in the marginal tax rates at the tax brackets cut-off points. From the analysis it becomes evident that individuals react to jumps in the marginal tax rate. First, an extension to the classical bunching approach introduced by Saez (2010) and extended by Chetty et al. (2011) is provided. Because individuals face optimisation frictions, perfect bunching at the kink as predicted by theory is not observable. Rather, a window around the kink, known as the bunching window, is used in the analysis. Where prior research had relied on visual inspection to determine the size of the bunching window, a data-driven procedure is proposed instead, which is shown to be robust to variations in various parameters and takes away the researchers discretion in that matter. Thus, a methodological contribution to a comparably young, but growing field of research is made. Chapter 3 discusses the implications of the introduction of transfer pricing regulations (TPR) on intermediate goods trade. The chapter thus analyses an anti-avoidance measure implemented by many governments in recent years and evaluates the consequences for allocative and distributional efficiency. The empirical literature has shown that multinational enterprises (MNEs) utilise transfer prices to shift profits into (out of) low-tax (high-tax) jurisdictions. Evidence was given in prior literature that MNEs react sensitively to the introduction of TPR in reducing (increasing) their prices when they were overvalued (undervalued) before the implementation of regulations. Surprisingly, a reaction in quantities, i.e. shifts in production and trade flows, had not been analysed in the literature before. The results indicate a substantial quantity reaction and also a pricing reaction, which is shown to be in line with the literature. This suggests that before the introduction of TPR, firms shift more exports to low tax countries and less exports to high tax countries for tax optimising purposes. Following the introduction of TPR, especially the reduction in quantities traded with low tax countries is identified. Chapter 4 deals with a recently developed tax incentive for research and development (R&D), namely the intellectual property box (IP-Box). Said to foster innovation by the implementing governments, critics accuse the IP-Box regimes of providing yet another profit shifting opportunity for multinational enterprises (MNEs). The study assesses the implications that the introduction of IP-Box regimes has on innovation and shifting behaviour, in order to judge on the efficiency and effectiveness of such a policy instrument. Whilst most R&D incentives are ex ante tax incentives, i.e. incentives that act during the innovation process and before the innovative product was developed, IP-Boxes are an ex post tax incentive, thus only benefiting successful R&D. The analysis attempts to explore whether IP-Boxes are a local innovation enhancing device, as propagated by the countries implementing IP-Boxes, or merely facilitate profit shifting for MNEs by offering a substantially lower tax rate on income from intellectual property. The results clearly show that the shifting channel dominates the home innovation channel. Some evidence is found that home developed patents were crowded out by foreign developed and subsequently shifted patents. The total number of patents does not seem to react to the introduction of IP-Boxes, thus even questioning the global innovation enhancing effect of IP-Boxes. Given the nature of the country level data, it is not possible to investigate the different designs of IP-Boxes more thoroughly, although the implementation of a development condition should be part of every IP-Box regime. This ensures that, at least from a global or even European perspective, innovation must take place somewhere.
The effect of transfer pricing regulations on intra-industry trade
(2017) Dekker, Vincent; Strohmaier, Kristina
We analyse the effect of transfer pricing regulations on trade ows. We base our estimation on a panel gravity model, where the transfer pricing regulations are modeled as trade costs. To abstract from any aggregate demand shocks, we focus on intermediate goods in the car industry. Our results suggest a significant volume effect on the exported quantity as a result of the introduction of transfer pricing laws in the exporting country. Exports to lower tax rate countries are reduced, whilst exports to higher tax rate countries are increased. In line with theory, transfer pricing regulations only play a role if a tax rate difference exists between the trading partners.
The impact of transfer pricing regulations on profit shifting within European multinationals
(2012) Lohse, Theresa; Riedel, Nadine
Over the past decade, several countries augmented their national tax law by transfer pricing legislations in order to limit opportunities for tax- motivated transfer price distortions and the associated relocation of multna- tional income from their borders. The aim of this paper is to empirically investigate the impact of transfer pricing laws on multinational profit shifting behaviour. To do so, we collect unique data on the evolution of national trans- fer price requirements in Europe over the past decade. This data is linked to accounting information on multinational firms in the EU and to corporate tax rate data. In line with previous studies, we find that multinational firms engage in significant tax-motivated profit shifting behaviour. The analysis fur- thermore suggests that transfer price documentation rules are instrumental in restricting income shifting activities. The effect is statistically significant and economically relevant. Our analysis thus underpins the benefits of im- plementing transfer price documentation requirements and suggests that they may be socially desirable despite the high administrative burden they impose on firms and tax authorities.