Profit repatriation of a Polish subsidiary from tax planning point of view of an international corporation

The main purpose of this study was to examine and compare the possibilities of profit repatriation from the point of view of tax planning of an international corporation, in such a case that a Finnish parent company has a subsidiary in Poland. The main research problem was divided into two sub research problems: 1) to examine concepts and principles of international taxation and tax planning from the point of view of international corporations and 2) to discuss the main features of Polish Companies-, Accounting- and Tax Act from the point of view a Finnish parent company. The research method of this study is mainly decision making, comparative analysis. In this study have been discussed the possibilities of international profit repatriation for supporting the decision making of the management of a Finnish parent company. In addition different repatriation possibilities have been compared. In this study has been noticed that a Finnish parent company can repatriate profit of its Polish subsidiary either directly as dividends or by using indirect methods such as interests, royalties, management fees and transfer pricing of goods. The total tax burden of dividends is heavier than the tax burden of indirect methods. It was also concluded that during the last years the Polish legislation has been renewed in order to prevent hidden dividend distribution. This has been done by implementing new rules of transfer pricing and thin capitalization.

Internationalization dynamics in the Swiss Corporate Tax Reform III

Over the last years, in a context of international tax competition, international and regional institutions such as the G20, the OECD, and the European Union are redefining what is acceptable in terms of corporate fiscal policy. Certain Swiss preferential tax treatments are considered by the above-mentioned institutions as harmful tax practices. As a consequence, the Swiss government has planned a third corporate tax reform (CTR III). The objective of this reform is to ensure international acceptability of the corporate tax system without prejudicing local public finances and Swiss corporate tax attractiveness. Therefore, we can posit that the CTR III is an internationalized object influenced by both regulation trends and tax competition framework. The main purpose of this paper is to provide elements of answer on how the currently discussed CTR III is influenced by the international environment, by focusing on its content as well as the reactions and positions of local stakeholders. With the help of internationalization literature, two distinct internationalization processes have been identified through the propositions of compliance measures with internationally-defined standards and competitiveness-enhancing measures. With regard to the configuration of local actors, the degree of conflict seems to be rather high. The current content of the reform is supported by the business community and right-wing parties and rejected by the unions and the Socialist Party.

Disclosure of tax information -from tax reporting system to the financial statements, Case: Fortum Oyj

The main target of the study was to examine how Fortum’s tax reporting system could be developed in a way that it collects required information which is also easily transferable to the financial statements. This included examining disclosure requirements for income taxes under IFRS and US GAAP. By benchmarking some Finnish, European and US companies the purpose was to get perspective in what extend they present their tax information in their financial statements. Also material weakness, its existence, was under examination. The research method was qualitative, descriptive and normative. The research material included articles and literature of the tax reporting and standards relating to it. The interviews made had a notable significance. The study pointed out that Fortum’s tax reporting is in good shape and it does not require big changes. The biggest renewal of the tax reporting system is that there is only one model for all Fortum’s companies. It is also more automated, quicker, and more efficient and it reminds more the notes in its shape. In addition it has more internal controls to improve quality and efficiency of the reporting process.

Incumbent audit firm-provided tax services and the clients with low financial reporting quality

This study investigates whether incumbent audit firm-provided tax services enhance or impair the likelihood of acknowledging client companies’ low financial reporting quality. In particular, we examine the association between tax-related fees and the likelihood of timely restatements, and internal control weakness disclosures among a sample of US companies that all have misstatements in financial information. The empirical findings indicate that companies paying higher tax-related fees are less likely to disclose SOX 404 internal control weakness disclosures, implying that underlying control problems are unacknowledged when incumbent audit firm provided tax-related fees are higher. However, the findings suggest that just providing both audit and tax-related services does not have an impact on audit quality per se, but rather it is the magnitude of the tax-related fees in particular that counts. We also find some evidence suggesting that companies paying higher tax-related fees have higher likelihood of restatement lags, whereas companies paying smaller tax-related fees to their audit firm restate financial statements in a timelier manner. Overall, the findings suggest that audit scrutiny of client companies with low quality financial reporting is weaker when the magnitude of tax-related fees is higher.

Effects of a Financial Transaction Tax - Do Transaction Costs Lower Volatility?: A Literature Review

In this literature review the theorethical framework of Financial transaction taxes and their assumed effect on market volatility is assessed. The empirical evidence from various studies is compared against the theory and a simple empirical review of the Finnish stock market is conducted. The findings implicate that financial transaction taxes can not reduce volatility and their actual effect on markets is dependend by many other factors as well. Some evidence even suggests that transactions taxes may actually raise volatility.

In vivo fluctuation of Tax, Foxp3, CTLA-4, and GITR mRNA expression in CD4+CD25+ T cells of patients with human T-lymphotropic virus type 1-associated myelopathy

HTLV-1 Tax expression exerts an inhibitory effect on the Foxp3 transcription factor in CD4+CD25+ T-regulatory cells (Treg). For a better understanding of the role of Tax mRNA in the gene expression of cellular markers we measured Tax, Foxp3, CTLA-4, GITR, TGF-β, and IL-10 mRNA in Treg cells of 50 patients with human T-lymphotropic virus type 1 (HTLV-1)-associated myelopathy/tropical spastic paraparesis (HAM/TSP; 27 women and 23 men; mean age: 56.7 years). The control group consisted of 23 non-infected subjects (12 women and 11 men) with a mean age of 51.3 years. Real-time PCR was used to measure mRNA of Tax proteins and several cellular markers of Treg function. Determinations revealed a high level of Tax mRNA in HAM/TSP (124.35 copies/100 CD4+CD25+ T cells). Foxp3, GITR, and CTLA-4 mRNA levels were lower in HAM/TSP patients (mean ± SD, 22.07 ± 0.78, 9.63 ± 0.36, and 4.54 ± 0.39, respectively) than in non-infected controls (47.15 ± 12.94, 22.14 ± 1.91, and 21.07 ± 2.31). Both groups had similar levels of TGF-β and IL-10. An inverse relationship was found between Tax levels and Foxp3, CTLA-4, and GITR levels. Conversely, there was a direct correlation between levels of Foxp3, GITR, and CTLA-4. Disease severity and evolution time did not correlate with Tax or Foxp3 levels. The present results suggest that Tax and Foxp3 mRNA vary with the same degree of disease severity in HAM/TSP patients. Tax fluctuations may affect CTLA-4 and GITR expression via the Foxp3 pathway, causing virus-induced dysfunction of CD4+CD25+ T cells in HAM/TSP patients.

An evaluation of the 2003 tax reform effort in Brazil

This paper provides an assessment of the tax-reform effort launched by the newly elected Lula government in 2003. It analyzes how the envisaged reform had to be changed and scaled down, in the wake of strong political resistance, after a failed attempt to develop a consensual proposal, fully supported by state-governors. The main effective changes are then evaluated. Challenges ahead are discussed at the end.

A graphic explanation on how a tax on exports neutralizes the Dutch disease without costs to exporters

The adequate way of neutralizing the Dutch disease is the imposition of a variable tax on the export of the commodity that originates the disease. If such tax is equivalent to the "size" of the Dutch disease, it will shifts to the right its supply curve of the commodity in relation to the exchange rate, giving the existing domestic supply and the international demand, the exchange rate will depreciate at the value of the tax, and the equilibrium exchange rate will move from the "current" to the "industrial" equilibrium.

Invoice-kaupan edut ja haitat verrattuna tavalliseen Tax Free kauppaan

Kandidaatintutkielmani käsittelee Invoice-kauppaa ja sitä, mitä etuja siihen liittyy verrattuna tavanomaiseen tax-free kauppaan. Invoice-veronpalautusjärjestelmässä EU:n ulkopuolella asuva asiakas saa veronpalautuksen samasta liikkeestä seuraavalla asiointikerralla. Arvonlisäveronpalautukset on kuitenkin haettava puolen vuoden sisällä ostosten tekemisestä. Tavanomaisessa tax-free kaupassa asiakas saa arvonlisäveronpalautuksen rajalta poistuessaan Suomesta. Invoicea käytettäessä asiakas saa verosta isomman osan takaisin kuin tavanomaisessa tax-free kaupassa, mutta palautuksen saaminen kestää kauemmin, koska Invoicea käytettäessä veronpalautuksen voi saada vain samasta liikkeestä, missä ostokset on tehty. Tutkielmani tarkastelee aihetta kauppiaan näkökulmasta. Kauppiaan kannalta Invoicen etuna on erityisesti asiakkaiden ”koukuttaminen”, koska veronpalautukset on aina haettava samasta liikkestä, mistä tuotteet on ostettu. Näin samat asiakkaat tulevat usein samaan liikkeeseen myös seuraavilla Suomen matkoilla saadakseen veronpalautukset. Tämä tuo liikkeille usein myös uusia kanta-asiakkaita.Toisaalta on huomioitava myös Invoicen käytöstä kauppiaalle ja kassoille mahdollisesti aiheutuva lisätyö ja kustannukset. Veronpalautusten maksaminen takaisin asiakkaille ja tullissa leimattujen kuittien käsittely vie kassoilla tavanomaista enemmän aikaa ja saattaa vaatia lisää henkilökuntaa. Tutkielma on toteutettu laadullisena eli kvalitatiivisena ja tutkimusmenetelmänä on käytetty haastatteluita. Haastateltavat ovat kauppiaita Kaakkois-Suomen alueelta. Tavoitteenani oli koota mahdollisimman monipuolinen haastateltavien joukko sisältäen niin vaate- ja vapaa-ajan liikkeitä kuin sekatavara- ja päivittäistavarakauppoja. Teorialähteinä käytin yliopiston kirjastosta lainattuja kirjoja, LUT:in tietokantojen ja Edilex-tietokannan artikkeleita sekä Verohallinnon dokumentteja ja verkkojulkaisuja. Lisäksi olen hyödyntänyt tutkielmassani myös ajankohtaisia uutisia sekä erilaisten paikallis- ja aikakauslehtien artikkeleita. Tutkielmani johtopäätöksissä tulin siihen tulokseen, että kauppiaan kannalta edullisinta on käyttää samanaikaisesti sekä Invoicea että perinteistä, palautusliikeiden palveluja hyödyntävää tax-free järjestelmää. Tämä mahdollistaa liikkeille mahdollisimman laajan asiakasjoukon. Suomessa usein käyvät ostosmatkailijat suosivat yleensä Invoicea täysimääräisen veronpalautuksen vuoksi. Palautusliikkeet taas veloittavat asiakkaalle maksettavasta veronpalautuksesta oman palvelumaksunsa. Suomessa harvemmin vieraileville taas palautusliikkeiden palvelut ovat edullisempia, sillä veronpalautukset saa rajalta maasta poistuttaessa, eikä tarvitse palata samaan liikkeeseen puolen vuoden sisällä. Palautusliikkeiden etuna Invoiceen nähden on myös asioinnin vaivattomuus, sillä eri liikkeissä asioivat ostosmatkailijat saavat kaikista matkalla tekemistään ostoksista arvonlisäveronpalautuksensa yhdestä paikasta sen sijaan, että kävisivät hakemassa ne joka liikkeestä erikseen.

Understanding round-tripping phenomenon in Russian context – case Cyprus

Russian FDI has a few peculiarities. One of them is round-tripping. Round-tripping is defined as transfer of funds abroad, usually to offshore financial centers (OFCs), and then bringing all or some of the investment back as foreign investment. Russian context was chosen for this study because the share of round-tripping investments from country’s total FDI is extensive. However, it needs to be addressed that this is not just a Russian phenomenon. Round-tripping is used by many developed and developing countries, and most of the countries have their own designated destinations for this kind of capital, much like Cyprus is the main destination for Russian capital. It is important to study this phenomenon further, since it falsifies FDI statistics and can lead to poor decisions on state level. Theoretical part of the study tries to determine weather traditional FDI and internationalization theories fit to explain the Russian round-tripping phenomenon. Traditional FDI and internationalization theories are first introduced in general terms, and then further examined in Russian context. In traditional endogenic FDI theories, when the capital is formed in one country it goes abroad to find better profits. At a first glance, this seemed not to be the case in round-tripping. However, during the study it became rather clear that with few adjustments and changes in perspective, traditional theories could be used to explain round-tripping phenomenon. For example, OLI paradigm can be further developed into OLIH paradigm with ‘H’ representing the important home country institutions. Transaction based view and resource seeking theories were also seen well equipped to explain round-tripping with a change in perspective. The latter part of the study focused on holistic understanding of Russian –Cyprian investment relationship. Study aims to shed light into the determinants and consequences of this phenomenon for both countries involved. The two share historical, cultural and political ties, but most importantly common financial interests. Russian companies seek security and financial knowledge to maneuver their assets and Cyprian economy largely is dependent on their disproportionally large financial sector. Consequences for Cyprian economy were seen in current economic crisis, when the need for their financial services diminished. Russian government on the other hand is losing vast amounts of tax money due to this phenomenon. A rather extreme view was also introduced in this study. Round-tripping phenomenon and OFCs are an important reason why corruption exists, since if one does not have a way to make ill-gained money legitimate why try to ill-gain the money at the first place. The most important finding of the study is that round-tripping companies are in a better competitive position than genuine and purely domestic investor due to their institutional knowledge.

Property Tax Assessment - Niagara Township No. 179

A tax assessment of property no. 179 for Mr. Theodore Field or Mr. George Field. The total reads 546 and is dated October 25, 1886. Handwritten is "paid" with signature of J.Y.E. Cairns (collector).

List entitled “Total amount of ½ September paid” includes tax and supplies prices

List entitled “Total amount of ½ September paid” includes tax and supplies prices, n.d.

Tax Mimicking and Sub-National Entities : Evidence at the Municipal Level for Montreal, 2000 ?

Rapport de recherche

Political Influence, Economic Interests and Endogenous Tax Structure in a Computable Equilibrium Framework: with Applicatioon to the United States, 1973 and 1983

A full understanding of public affairs requires the ability to distinguish between the policies that voters would like the government to adopt, and the influence that different voters or group of voters actually exert in the democratic process. We consider the properties of a computable equilibrium model of a competitive political economy in which the economic interests of groups of voters and their effective influence on equilibrium policy outcomes can be explicitly distinguished and computed. The model incorporates an amended version of the GEMTAP tax model, and is calibrated to data for the United States for 1973 and 1983. Emphasis is placed on how the aggregation of GEMTAP households into groups within which economic and political behaviour is assumed homogeneous affects the numerical representation of interests and influence for representative members of each group. Experiments with the model suggest that the changes in both interests and influence are important parts of the story behind the evolution of U.S. tax policy in the decade after 1973.