Alternating offer games and private rulings of the Australian Tax Office

The concept of submitting oneself to a voluntary negotiation is by no means new to big business. Formal bargaining has been quite successful over the years in providing the venue for agents to explore a more logical and mathematical approach to bargaining. However in more recent times external influences have been applied to agents who provide better deals for favored executives. This external influence has displayed itself in taxtion negotiations to the extent that tax office agents have been dismissed for irresponsible conduct. We explore this specific type of negotiation using an alternating offer bargaining game to model the particular influences, which create unfair rulings in negotiations. By the constraints of this systematic mathematical approach to negotiation, we will explore the advantages of a more formal game theoretic approach. In this presentation we will also elaborate on finding Nash Equilibrium in alternating offer games.

Why does tax have to be so taxing? The Court revisits the Franked Investment Income litigation

Examines the European Court of Justice ruling in Test Claimants in the FII Group Litigation v Inland Revenue Commissioners (C-35/11) on whether the differential tax treatment of domestic and foreign-sourced dividends in the UK was compatible with the freedom of establishment and free movement of capital principles. Outlines its guidance on how to assess this compatibility. Considers the ruling's implications for the UK tax system, the relationship between tax sovereignty and the internal market and the third-country dimension of the free movement of capital principle.

What determines tax haven FDI

This paper examines the determinants of a multinational enterprise’s (MNEs) decision to invest in countries classified as tax havens. To the best of our knowledge this has not been analysed at the cross-country level before. We use the ownership-location-internalisation (OLI) paradigm and link it with financial specific advantages to develop a number of hypotheses which are subsequently tested by our empirical model. Our analysis is based on a large firm-level database covering 39,543 MNEs across the world for the period 2002- 2011. We find that higher corporate taxes faced by MNEs at home increase the likelihood of locating in a tax haven. Moreover, high technology manufacturing and services MNEs that possess large levels of intangible assets are also more likely to locate subsidiaries in tax havens. Finally, we find evidence that MNEs from countries with a more coordinated market orientation are less likely to locate in tax havens.

Bureaucratic reform in post-Asian crisis Indonesia:the Directorate General of Tax

Our research examines a key aspect of the extensive bureaucratic reform program that was applied to the Indonesian public sector following the Asian Economic crisis. The organisation we focus on is the Indonesian Directorate of Tax. The reforms moved the case organisation towards more bureaucratic organisational arrangements. The most notable elements of the reforms related to the organisational efficiency and changes in administrative style and culture. An ethnographic approach was adopted, in which the researcher was immersed in the life of the selected case organisation over an extended period of time. This research extends a thin literature on the topic of management control and culture in the Indonesian context. Also, this paper fills a gap in the theoretic approaches for studying bureaucracy, which is dominated by western conceptualisations. This paper provides a reminder to policy makers (including organisation such as the World Bank and the International Monetary Fund) of the consequences of neglecting cultural influences when conducting bureaucratic reform.

The determinants of tax haven FDI

This paper examines the determinants of a multinational enterprise’s (MNEs) decision to set up tax haven subsidiaries. We adapt the Firm-specific advantage–Country-specific advantage (FSA–CSA) framework and construct a number of empirically testable hypotheses. The analysis is based on a database covering 14,209 MNEs in twelve OECD countries. We find that the variety of capitalism of a MNEs home location and the level of technological intensity has a strong impact on this decision. We also find that the home country corporate tax rate has a minimal impact. This suggests that corporate tax liberalisation is unlikely to deter MNEs from undertaking this activity.

Tax implications of dividend policy

This study examines the tax-arbitrage possibilities on the Budapest Stock Exchange between 1995 and 2007. The theoretical possibility for the arbitrage is the different taxation for different stockholders, for the private investors and for the institutions: the institutions had higher taxation on capital gain while private persons in the whole period had tax-benefits on capital gains. The dynamic clientele model shows, that there is a range of the price drops after dividend payouts which guarantees a risk-free profit for both parties. The research is based on the turnover data from 97 companies listed on the Budapest Stock Exchange. We have tested the significant turnovers around the dividend-dates. The study presents clear evidence that investors continuously did take advantages on the different taxation.

Financial Transaction Tax: Small is Beautiful

The case for taxing financial transactions merely to raise more revenues from the financial sector is not particularly strong. Better alternatives to tax the financial sector are likely to be available. However, a tax on financial transactions could be justified in order to limit socially undesirable transactions when more direct means of doing so are unavailable for political or practical reasons. Some financial transactions are indeed likely to do more harm than good, especially when they contribute to the systemic risk of the financial system. However, such a financial transaction tax should be very small, much smaller than the negative externalities in question, because it is a blunt instrument that also drives out socially useful transactions. There is a case for taxing over-the-counter derivative transactions at a somewhat higher rate than exchange-based derivative transactions. More targeted remedies to drive out socially undesirable transactions should be sought in parallel, which would allow, after their implementation, to reduce or even phase out financialtransaction taxes.