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.

Performance benchmarking and incentive regulation – considerations of directing signals for electricity distribution companies

After the restructuring process of the power supply industry, which for instance in Finland took place in the mid-1990s, free competition was introduced for the production and sale of electricity. Nevertheless, natural monopolies are found to be the most efficient form of production in the transmission and distribution of electricity, and therefore such companies remained franchised monopolies. To prevent the misuse of the monopoly position and to guarantee the rights of the customers, regulation of these monopoly companies is required. One of the main objectives of the restructuring process has been to increase the cost efficiency of the industry. Simultaneously, demands for the service quality are increasing. Therefore, many regulatory frameworks are being, or have been, reshaped so that companies are provided with stronger incentives for efficiency and quality improvements. Performance benchmarking has in many cases a central role in the practical implementation of such incentive schemes. Economic regulation with performance benchmarking attached to it provides companies with directing signals that tend to affect their investment and maintenance strategies. Since the asset lifetimes in the electricity distribution are typically many decades, investment decisions have far-reaching technical and economic effects. This doctoral thesis addresses the directing signals of incentive regulation and performance benchmarking in the field of electricity distribution. The theory of efficiency measurement and the most common regulation models are presented. The chief contributions of this work are (1) a new kind of analysis of the regulatory framework, so that the actual directing signals of the regulation and benchmarking for the electricity distribution companies are evaluated, (2) developing the methodology and a software tool for analysing the directing signals of the regulation and benchmarking in the electricity distribution sector, and (3) analysing the real-life regulatory frameworks by the developed methodology and further develop regulation model from the viewpoint of the directing signals. The results of this study have played a key role in the development of the Finnish regulatory model.

The determinants of contractual choice for private involvement in infrastructure projects in the United States

Reliance on private partners to help provide infrastructure investment and service delivery is increasing in the United States. Numerous studies have examined the determinants of the degree of private participation in infrastructure projects as governed by contract type. We depart from this simple public/private dichotomy by examining a rich set of contractual arrangements. We utilize both municipal and state-level data on 472 projects of various types completed between 1985 and 2008. Our estimates indicate that infrastructure characteristics, particularly those that reflect stand alone versus network characteristics, are key factors influencing the extent of private participation. Fiscal variables, such as a jurisdiction’s relative debt level, and basic controls, such as population and locality of government, increase the degree of private participation, while a greater tax burden reduces private participation.

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.

Profitability Analysis of Service Contracts of Devices

The objective of this study has been to make a profitability analysis of service contracts for a company in Finland. The purpose has been to see how profitable the contracts are and if there possibly were some things to change or develop in the contracts. Allocation rules of cost accounting, service costs both profitability and management of services have been considered in the theory part. All the service contracts that have been valid at least three last accounting periods have been included in the study. All direct costs relating to the contracts have been collected and indirect costs have been assigned to the contracts. Profitability of the contracts has been calculated over three years. Results have been analyzed according to the key figures the company is controlling. Some suggestions for developments have been given at the end of the study. The study has shown differences between the contracts. Part of them has turned out to be like the profitability aims of the company and part less profitable. The study has shown that many factors have an effect on the profitability of the service contracts.

Are Public Private Partnerships that Rigid ? And Why ? : Evidence from Toll Road Concession Contracts

Transport concession contracts are commonly said to be standardized and too rigid. They would not allow public authorities to adapt them to evolving context and circumstances. This paper aims at challenging this view and, more particularly, the view that contractual rigidity for transport concessions is exogenous. Using a transaction cost framework, we disentangle between three main determinants of contractual rigidity: traffic uncertainty; connivance between contracting parties; quality of the institutional environment. Using an original database of toll road concession contracts, we observe a great variety of provisions for toll adjustment. We find that these exogenous determinants significantly influence contractual choices.

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.

Regulating Concessions of Toll Motorways, An Empirical Study on Fixed vs. Variable Term Contracts

Recent theoretical developments on concession contracts for long term infrastructure projects under uncertain demand show the benefits of allowing for flexible term contracts rather than fixing a rigid term. This study presents a simulation to compare both alternatives by using real data from the oldest Spanish toll motorway. For this purpose, we analyze how well the flexible term would have performed instead of the fixed length actually established. Our results show a huge reduction of the term of concession that would have dramatically decreased the firm’s benefits and the user’s overpayment due to the internalization of an unexpected traffic increase.

Counteracting incentive sensitization in severe alcohol dependence using deep brain stimulation of the nucleus accumbens: clinical and basic science aspects

The ventral striatum / nucleus accumbens has been implicated in the craving for drugs and alcohol which is a major reason for relapse of addicted people. Craving might be induced by drug-related cues. This suggests that disruption of craving-related neural activity in the nucleus accumbens may significantly reduce craving in alcohol-dependent patients. Here we report on preliminary clinical and neurophysiological evidence in three male patients who were treated with high frequency deep brain stimulation of the nucleus accumbens bilaterally. All three had been alcohol dependent for many years, unable to abstain from drinking, and had experienced repeated relapses prior to the stimulation. After the operation, craving was greatly reduced and all three patients were able to abstain from drinking for extended periods of time. Immediately after the operation but prior to connection of the stimulation electrodes to the stimulator, local field potentials were obtained from the externalized cables in two patients while they performed cognitive tasks addressing action monitoring and incentive salience of drug related cues. LFPs in the action monitoring task provided further evidence for a role of the nucleus accumbens in goal-directed behaviors. Importantly, alcohol related cue stimuli in the incentive salience task modulated LFPs even though these cues were presented outside of the attentional focus. This implies that cue-related craving involves the nucleus accumbens and is highly automatic.

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.

Does speed matter? : the impact of the EU membership incentive on rule adoption in minority language rights protection

Denna avhandling tar sin utgångspunkt i ett ifrågasättande av effektiviteten i EU:s konditionalitetspolitik avseende minoritetsrättigheter. Baserat på den rationalistiska teoretiska modellen, External Incentives Model of Governance, syftar denna hypotesprövande avhandling till att förklara om tidsavståndet på det potentiella EU medlemskapet påverkar lagstiftningsnivån avseende minoritetsspråksrättigheter. Mätningen av nivån på lagstiftningen avseende minoritetsspråksrättigheter begränsas till att omfatta icke-diskriminering, användning av minoritetsspråk i officiella sammanhang samt minoriteters språkliga rättigheter i utbildningen. Metodologiskt används ett jämförande angreppssätt både avseende tidsramen för studien, som sträcker sig mellan 2003 och 2010, men även avseende urvalet av stater. På basis av det \"mest lika systemet\" kategoriseras staterna i tre grupper efter deras olika tidsavstånd från det potentiella EU medlemskapet. Hypotesen som prövas är följande: ju kortare tidsavstånd till det potentiella EU medlemskapet desto större sannolikhet att staternas lagstiftningsnivå inom de tre områden som studeras har utvecklats till en hög nivå. Studien visar att hypotesen endast bekräftas delvis. Resultaten avseende icke-diskriminering visar att sambandet mellan tidsavståndet och nivån på lagstiftningen har ökat markant under den undersökta tidsperioden. Detta samband har endast stärkts mellan kategorin av stater som ligger tidsmässigt längst bort ett potentiellt EU medlemskap och de två kategorier som ligger närmare respektive närmast ett potentiellt EU medlemskap. Resultaten avseende användning av minoritetsspråk i officiella sammanhang och minoriteters språkliga rättigheter i utbildningen visar inget respektive nästan inget samband mellan tidsavståndet och utvecklingen på lagstiftningen mellan 2003 och 2010.