Suchergebnisse

As a part of the provisions governing the subject of the measurement of the income of business enterprises, the fifth paragraph, sub­ paragraph b), of article 53 of the Presidential Decree no. 597 of 29 September, 1973, provides, as it is well known, that "the difference between the normal value of goods and services, and the consideration for transfers made and for services rendered to companies, whose legal seat or administrative headquarters and whose main object are not in the Italian territory, and which either directly or indirectly control the enterprise, or are controlled by the same company that controls the enterprise", is tobe included in the proceeds. The second paragraph of the successive article 56 further states that the cost of acquisition of the goods transferred and of the services rendered by the same enterprises is to be curtailed of any surplus tn respect of the normal value. The same provision also applies to the goods transferred and the services rendered by companies not having in Italy their legal seat or their administrative office or the main object of their activity, for account of which the enterprise carries out an activity for the sale and placement of raw materials or goods, or for the manufacturing or processing of products.

Benutzerkommentar

There is a growing concern that governments lose substantial corporate tax revenue because of profit shifting through transfer-pricing and thin-capitalization strategies. Existing literature studies profit shifting and transfer pricing separately. In practice, the choice of debt-to-asset ratios in affiliates and the transfer price of debt are interrelated management decisions that are also mutually affected by government regulation. This paper models these strategies as intertwined. We find that the tax sensitivity of the corporate tax base depends on whether the debt shifting and transfer pricing are cost complements or substitutes. A second result is that stricter regulation of debt shifting (transfer pricing) can potentially increase the use of transfer pricing (debt shifting) and thus the amount of profits shifted.