Keeping it Simple–Efficiency Costs of Fixed Margin Regimes in Transfer Pricing
Keeping it Simple–Efficiency Costs of Fixed Margin Regimes in Transfer Pricing

Author: Sebastian Beer

Publisher: International Monetary Fund

Published: 2022-09-23

Total Pages: 27

ISBN-13:

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Simplifying tax policy comes with costs and benefits. This paper explores simplification options for the taxation of MNEs, an area where administrative and compliance costs of the current rules are large. Simplified approaches seek to reduce these costs by relying on an approximation of the true tax base, potentially distorting resource allocation. We examine the efficiency cost of transfer pricing simplification theoretically and empirically. Using a sample of 300,000 firms located in 22 countries, we estimate that common transfer pricing practices reduce efficiency between 0.25 and 2.2 percent of total factor productivity across sectors. Focusing on the manufacturing sector, we then observe that simplification more than doubles sectoral inefficiency on average. However, large differences exist, with moderate efficiency costs in several sectors.

Fiscal Regimes for Extractive Industries—Design and Implementation
Fiscal Regimes for Extractive Industries—Design and Implementation

Author: International Monetary Fund. Fiscal Affairs Dept.

Publisher: International Monetary Fund

Published: 2012-08-16

Total Pages: 82

ISBN-13: 1498340067

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Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación

Introduction to Transfer Pricing
Introduction to Transfer Pricing

Author: Jerome Monsenego

Publisher:

Published: 2013-01-01

Total Pages: 163

ISBN-13: 9789144092706

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Transfer pricing is an area of tax law that has significantly expanded over the last decades. With the globalisation of business activities, the threat of international double taxation, and the need for States to monitor transfer prices to avoid the illegitimate erosion of their tax base, transfer pricing has become a key question for multinational enterprises and tax administrations. The book provides a general overview on the fundamentals of transfer pricing from an OECD perspective. The book also illustrates the fundamentals of transfer pricing with concrete examples based on the structures often used by multinational enterprises when entering into cross-border intercompany transactions. This book is primarily addressed to students reading international tax courses, but may also be of use to tax professionals in matters pertaining to transfer pricing.

International Business Taxation
International Business Taxation

Author: Sol Picciotto

Publisher: Praeger

Published: 1992-03-02

Total Pages: 424

ISBN-13:

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This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.

International Corporate Tax Reform
International Corporate Tax Reform

Author: International Monetary

Publisher: International Monetary Fund

Published: 2023-02-06

Total Pages: 59

ISBN-13:

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To relieve the pressure on the outdated international corporate tax system, an ambitious reform was agreed at the Inclusive Framework (IF) on Base Erosion and Profit Shifting in 2021, with now 138 jurisdictions joining. It complements previous efforts to mitigate profit shifting by addressing the challenges of the digitalization of the economy through a new allocation of taxing rights to market economies (Pillar 1) and tax competition through a global minimum corporate tax (Pillar 2). This paper concludes that the agreement makes the international tax system more robust to tax spillovers, better equipped to address digitalization, and modestly raises global tax revenues.

Fiscal Monitor, April 2022
Fiscal Monitor, April 2022

Author: International Monetary Fund

Publisher: International Monetary Fund

Published: 2022-04-20

Total Pages: 124

ISBN-13: 1513598783

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Chapter 1 discusses how fiscal policy operates amid a sharp rise in uncertainty caused by the war in Ukraine. Chapter 2 discusses how international coordination on tax matters can support revenue, inclusion, tax transparency, and greener economies.

Exploring Residual Profit Allocation
Exploring Residual Profit Allocation

Author: Sebastian Beer

Publisher: International Monetary Fund

Published: 2020-02-28

Total Pages: 51

ISBN-13: 1513528327

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Schemes of residual profit allocation (RPA) tax multinationals by allocating their ‘routine’ profits to countries in which their activities take place and sharing their remaining ‘residual’ profit across countries on some formulaic basis. They have recently and rapidly come to prominence in policy discussions, yet almost nothing is known about their impact on revenue, investment and efficiency. This paper explores these issues, conceptually and empirically. It finds residual profits to be substantial, but concentrated in a relatively few MNEs, headquartered in few countries. The impact on tax revenue of reallocating excess profits under RPA, while adverse for investment hubs, appears beneficial for lower income countries even when the formula allocates by destination-based sales. The impact on investment incentives is ambiguous and specific both to countries and MNE groups; only if the rate of tax on routine profits is low does aggregate efficiency seem likely to increase.

The Costs of Taxation and the Marginal Cost of Funds
The Costs of Taxation and the Marginal Cost of Funds

Author: Mr.Joel Slemrod

Publisher: International Monetary Fund

Published: 1995-08-01

Total Pages: 32

ISBN-13: 1451954549

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It is argued that taxation causes three kinds of deadweight losses and two types of direct costs. The deadweight losses arise from substitution, evasion, and avoidance activities while the direct costs are administrative and compliance costs. Some of these social costs tend to be discontinuous and/or nonconvex. Because most models of taxation ignore some components of the social costs of taxation, their conclusions cannot be of a general nature. An alternative approach to policy evaluation is to rely on a marginal efficiency cost of funds rule which can indicate appropriate directions of reforms. The paper discusses its merits, applicability, and limitations, as well as its relationship to other concepts.

International Transfer Pricing
International Transfer Pricing

Author: Business International Corporation

Publisher:

Published: 1991

Total Pages: 212

ISBN-13:

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A comprehensive guide to corporate practices in internal control and tax compliance. Included are case studies of how firms in a variety of industries approach transfer pricing.