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.

How Party Linkages Shape Austerity Politics: Clientelism and Fiscal Adjustment in Greece and Portugal during the Eurozone Crisis

Drawing on an analysis of austerity reforms in Greece and Portugal during the sovereign debt crisis from 2009 onwards, we show how the nature of the linkages between parties and citizens shapes party strategies of fiscal retrenchment. We argue that parties which rely to a greater extent on the selective distribution of state resources to mobilize electoral support (clientelistic linkages) are more reluctant to agree to fiscal retrenchment because their own electoral survival depends on their ability to control state budgets to reward clients. In Greece, where parties relied extensively on these clientelistic linkages, austerity reforms have been characterized by recurring conflicts and disagreements between the main parties, as well as a fundamental transformation of the party system. By contrast, in Portugal, where parties relied less on clientelistic strategies, austerity reforms have been more consensual because fiscal retrenchment challenged to a lesser extent the electoral base of the mainstream parties.

Europeanization or Party Politics? Explaining Government Choice for Corporatist Concertation

This article assesses whether changes in government choice for policy concertation with trade unions and employers are better explained by international or domestic factors. We compare patterns of corporatist governance in a strongly Europeanized policy domain (labor migration policy) and in a weakly Europeanized policy domain (welfare state reforms) over the last 20 years in Austria and Switzerland. We show that there is no systematic difference in patterns of concertation between the two policy sectors and that factors linked to party politics play a bigger role in the choice of governments for concertation. If the base of party support for policies is divided, governments are more prone to resort to corporatist concertation as a way to build compromises for potentially controversial or unpopular policies. By contrast, ideologically cohesive majority coalitions are less prone to resort to concertation because they do not need to build compromises outside their base of party support.

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.

Speed limit laws in America: economics, politics and geography

The regulation of speed limits in the US had been centralized at the federal level since 1974, until decisions were devolved to the states in 1995. However, the centralization debate has reemerged in recent years. Here, we conduct the first econometric analysis of the determinants of speed limit laws. By using economic, geographic and political variables, our results suggest that geography -which affects private mobility needs and preferences- is the main factor influencing speed limit laws. We also highlight the role played by political ideology, with Republican constituencies being associated with higher speed limits. Furthermore, we identify the presence of regional and time dependence effects. By contrast, poor road safety outcomes do not impede the enactment of high speed limits. Overall, we present the first evidence of the role played by geographical, ideological and regional characteristics, which provide us with a better understanding of the formulation of speed limit policies.

Emotions in International Politics. Beyond Mainstream International Relations

In recent years, social scientists have increasingly recognized the interconnectedness of thought on emotions. Nowhere is the role of passions more evident than international politics, where pride, anger, guilt, fear, empathy, and other feelings are routinely on display. But in the absence of an overarching theory of emotions, how can we understand their role at the international level? Emotions in International Politics fills the need for theoretical tools in the new and rapidly growing subfield of international relations. Eminent scholars from a range of disciplines consider how emotions can be investigated from an international perspective involving collective players, drawing evidence from such emotionally fraught events as the Rwandan genocide, World War II, the 9/11 attacks, and the Iranian nuclear standoff. The path-breaking research collected in Emotions in International Politics will be a valuable theoretical guide to understanding conflict and cooperation in international relations.

Challenges and Opportunities of Online Entertainment. Proceedings of the 7th International Conference on Internet, Law & Politics. Universitat Oberta de Catalunya, Barcelona, 9-10 July, 2012.

El VIII Congrés Internacional Internet, Dret i Política (IDP 2012) que s'ha dut a terme a Barcelona els dies 9 i 10 de juliol de 2012 sota el títol genèric de "Reptes i oportunitats de l'entreteniment en línia", ha abordat alguns dels principals reptes als que s'enfronta la societat de la informació des de la perspectiva jurídica i politològica. Concretament, els temes centrals han estat el debat sobre l'entreteniment a la xarxa, així com altres qüestions relacionades amb Internet i els drets de propietat intel·lectual, la privacitat, la seguretat o la llibertat d'expressió.

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.

Internet, Law and Politics. A decade of transformations.

Proceedings of Internet, Law and Politics. A decade of transformations.